Bribery and Corruption Policy
Introduction
Kalamazoo Secure Solutions Ltd recognises that an essential element of corporate social responsibility is honest and transparent trading. Bribery and corruption create a disincentive to trade as well as uneven trading conditions that can damage economic systems and the individuals within them.
Kalamazoo Secure Solutions has a clear policy and we support our employees to make decisions in line with our stated position. Our conduct is based on our commitment to acting professionally, fairly and with integrity. Kalamazoo Secure Solutions Ltd does not tolerate any form of bribery and corruption.
Scope
This policy applies to Kalamazoo Secure Solutions Ltd employees (staff, contract and temporary) and associates.
Policy
Kalamazoo Secure Solutions Ltd does not engage in bribery or any form of unethical inducement or payment including facilitation payments and ‘kickbacks.’
We do not make direct or indirect contributions to political parties.
To avoid facilitating corruption, our internal and external Controls will concentrate on creating central registers of all persons involved in both procurement and sales, reviewing the commission of intermediaries, conducting due diligence of our business partners and inserting appropriate terms in our purchasing and sales contracts.
Our expenses policy and register of hospitality will set appropriate limits on hospitality given and accepted. As hospitality is open to interpretation, best practice is to neither offer nor accept hospitality during contractual negotiations.
No gifts of property or money should ever be accepted by employees from any person. If any person connected with our business offers any such gifts the offer must be reported to the Compliance team in writing.
We will uphold laws relevant to countering bribery and corruption in all the jurisdictions in which we operate, particularly laws that are directly relevant to specific business practices.
Responsibilities
We have appointed a Compliance team including an independent member. These persons will be responsible for the implementation of our internal and external controls.
Communications
We will communicate this policy and relevant guidance to employees through our established internal channels. We will also communicate this policy as appropriate to our suppliers, contractors and business partners and wider stakeholders.
Raising concerns and seeking guidance
Employees are encouraged to raise concerns about any instance of malpractice at the earliest possible stage via their line manager or to the Compliance team.
Employees will receive the full support of the Company when upholding this policy, even if it may result in the Company losing business.
Monitoring and review
This policy is reviewed and monitored through Management Review.