1. Policy Statement
Bash EcoCleaners Service Ltd has a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships, wherever we operate. We will uphold all laws relevant to countering bribery and corruption, including the Bribery Act 2010.
2. Scope
This policy applies to all individuals working at all levels of the organisation, including directors, employees, contractors, franchise partners, consultants, suppliers, and any person associated with the Company.
3. What Is Bribery?
Bribery is the offering, promising, giving, accepting, or soliciting of an advantage as an inducement for an action that is illegal, unethical, or a breach of trust. Under the Bribery Act 2010, there are four key offences:
- Bribing another person
- Being bribed
- Bribing a foreign public official
- Failure by a commercial organisation to prevent bribery
A bribe does not have to involve cash. It can include gifts, hospitality, favourable treatment, political or charitable contributions made to gain a business advantage, or any other benefit.
4. Prohibited Conduct
You must not:
- Offer, promise, give, or accept any bribe, whether cash or any other inducement
- Give or accept gifts or hospitality that could influence or appear to influence business decisions
- Make facilitation payments to speed up routine processes
- Offer favourable terms to clients or suppliers in return for personal benefit
- Engage any third party to act on your behalf in any way that would breach this policy
- Threaten or retaliate against anyone who has refused to commit a bribery offence or has raised concerns
5. Gifts & Hospitality
We recognise that reasonable and proportionate hospitality and gifts are a normal part of doing business. However:
- All gifts and hospitality worth more than £25 must be declared and recorded in the Gifts & Hospitality Register
- Gifts must never be offered or accepted during a tender or procurement process
- Cash gifts are never acceptable
- Any gift or hospitality that could create a sense of obligation must be declined
6. Public Sector Contracts
We are particularly vigilant in our dealings with public sector clients, including local authorities, housing associations, and NHS organisations. All procurement processes are conducted transparently and in full compliance with applicable procurement regulations.
7. Reporting Concerns
If you suspect or witness any bribery or corruption, you must report it immediately. You can:
- Report to your line manager or a director
- Use our confidential Whistleblowing Policy
- Email compliance@bashecocleanersservice.co.uk
All reports will be treated confidentially. No employee will suffer any detriment for reporting genuine concerns in good faith.
8. Consequences of Breach
Any breach of this policy will be treated as a serious disciplinary matter and may result in dismissal for gross misconduct. Bribery is a criminal offence carrying penalties of up to 10 years' imprisonment and unlimited fines.
9. Record Keeping
We maintain accurate financial records and have appropriate internal controls to evidence that business transactions are legitimate. All accounts, invoices, and documents relating to dealings with third parties are prepared with strict accuracy.
10. Review
This policy is reviewed annually by the Board of Directors. Training on anti-bribery and corruption is provided to all staff during induction and refreshed periodically.
Last updated: April 2026