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Anti-Bribery Policy 

Effective Date: 2016

Last Updated: 2021

Flying Fish UK Ltd is committed to conducting its business with the highest standards of integrity and fairness. We take a zero-tolerance approach to bribery and corruption and are dedicated to preventing bribery in all forms. This policy sets out our position on bribery and provides guidelines to staff, Instructors, examiners and any training partners.

The law.

The Bribery Act 2010 criminalises bribery and corruption, making it an offence to offer, promise, give, request, or accept a bribe. This policy ensures Flying Fish UK Ltd complies with the Act and reinforces our commitment to ethical business conduct.

Scope of the Policy

This policy applies to all individuals working for or on behalf of Flying Fish UK Ltd, including:

  • Staff, Instructors and examiners, whether full-time, part-time, temporary, or casual
  • Directors and officers
  • Any supplier that provides training, assessment or examination for Flying Fish UK Ltd

What is Bribery?

Bribery refers to offering, giving, receiving, or soliciting something of value (such as money, gifts, or favours) with the intention of influencing a decision or gaining an unfair advantage. The Bribery Act 2010 creates two main types of bribery offences:

Bribery can take many forms, including but not limited to:

  • Offering or receiving gift in return for favourable results during assessments or exams.
  • Payments made to secure business or contracts.
  • Payments are made to influence regulatory decisions or to avoid legal obligations.

Staff obligations

Flying Fish UK Ltd strictly prohibits any form of bribery, whether by our employees, contractors, suppliers or customers. Including:

  • Offering, promising, or giving bribes to any person.
  • Requesting, agreeing to receive, or accepting bribes from any person.
  • Any form of facilitation payments (payments made to speed up a process or gain preferential treatment).
  • Falsifying records.

Adequate Procedures to Prevent Bribery

Flying Fish UK Ltd has implemented adequate procedures to prevent bribery within our organisation, in line with the Bribery Act 2010. These procedures include:

Risk Assessment

We regularly assess bribery risks across our operations and supply chain. The risk assessment considers geographical areas, business relationships, and the type of work or services provided.

Due Diligence

We conduct due diligence on all third parties we work with, including suppliers and training partners to ensure they comply with our anti-bribery expectations.

Internal Controls

We maintain clear internal controls, including approval processes for gifts, entertainment, and financial transactions, to detect and prevent any bribery attempts.

Employee Training

All employees receive regular training on the risks associated with bribery, how to recognise bribery, and how to report concerns. Training is tailored to roles with the highest risk of exposure to bribery.

Reporting Mechanisms

Flying Fish UK Ltd has established a whistleblowing mechanism, allowing employees to report any concerns or suspicions of bribery confidentially without fear of retaliation.

Gifts, Hospitality, and Entertainment

While we recognise that business gifts, hospitality, and entertainment may form part of professional relationships, Flying Fish UK Ltd strictly prohibits the provision or acceptance of any gifts, entertainment, or hospitality that could influence, or be perceived to influence, a business decision.

Employees are required to:

  • Seek prior approval before giving or accepting any gifts or hospitality, irrespective of their value.
  • Ensure that gifts or hospitality are proportionate, reasonable, and consistent with established industry practices.
  • Avoid accepting or offering gifts that could create the appearance of a conflict of interest or improper influence.

Third-Party Relationships

Flying Fish UK Ltd holds all third parties we work with to the same high standards. We require that all suppliers, contractors, agents, and partners:

  • Comply with this Anti-Bribery Policy and the Bribery Act 2010.
  • Adopt their own anti-bribery measures where applicable and ensure these are consistent with our practices.
  • Provide assurances of their commitment to combat bribery and corruption.

Consequences of Breaching this Policy

Any employee found to be involved in bribery will face disciplinary action up to and including dismissal. In cases of bribery involving third parties, Flying Fish UK Ltd reserves the right to terminate contracts and relationships immediately.

In addition to internal disciplinary measures, violations of the Bribery Act 2010 may result in criminal charges, including imprisonment and/or fines, for individuals and companies found guilty of bribery offences.

Reporting Bribery

If you have any concerns or suspect that bribery has occurred, you are encouraged to report these concerns immediately. Reports can be made confidentially via:

  • Email: mail@flyingfishonline.com
  • Phone: +44 01983280641

Please ask for a director

All reports will be taken seriously and investigated thoroughly. Retaliation against employees who report bribery in good faith is strictly prohibited.

Policy Review and Updates

Flying Fish UK Ltd will review this Anti-Bribery Policy regularly to ensure its effectiveness and compliance with any changes in legislation. The policy will be updated as necessary and communicated to all relevant parties.