Business ethics statement

We believe that best practice governance, controls and compliance are essential for maximising reputation and shareholder value. To achieve this, our people will act with the highest standards of integrity and honesty in all they do, thereby helping our business partners and customers have confidence in their services levels when entrusting us with their business.

We recognise that bribery and corruption have an adverse effect on communities wherever they occur, so our people are committed to enforcing high moral and ethical standards in all our service levels and business activities.

The Bribery Act 2010 implemented on 1 July 2011, introduced changes in legislation that could significantly impact the conduct of a company’s business, in that:

It extended the crime of bribery to cover all private sector transactions (previously bribery offences were confined to transactions involving public officials and agents).
It created a new strict liability offence of failing to prevent bribery. An organisation will only have a defence to this offence if it can show it had "adequate procedures" in place to prevent bribery.
Its scope is extensive – the offences are very broadly defined, and it has significant extra-territorial reach.

The offences contained in the Bribery Act carry criminal penalties for individuals and organisations. For individuals, a maximum prison sentence of ten years and/or an unlimited fine can be imposed; for companies, an unlimited fine can be imposed.

As a result, we are committed to ensuring that our anti-corruption procedures are sufficiently robust to prevent corruption and to mitigate the risk of committing an offence under the Act.

The Act created four offences:

A general offence covering offering, promising, or giving a bribe.

A general offence covering requesting, agreeing to receive, or accepting a bribe.
A distinct offence of bribing a foreign public official to obtain or retain business.
A new strict liability offence for commercial organisations where they fail to prevent bribery by those acting on their behalf.

We understand that an employee performs services on behalf of his or her employer, and consequently companies will be liable for bribery committed by their employees. As a result, one of the key elements of the Act is the introduction of a new offence for corporate entities (including partnerships) of failure to prevent bribery being carried out on their behalf.

This offence is one of strict liability; if a corrupt act is carried out by the company, or by an associated person on its behalf, the company will automatically be guilty of the new offence, subject to the failure to have “adequate procedures” in place.

Bribery is defined as: "The offering, promising, giving, accepting or soliciting of an advantage as an inducement for an action which is illegal or a breach of trust."

Our anti-bribery commitment

At New Beginnings Consultation, we, our associates, and subsidiaries prohibit the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement to or from any person or company, wherever they are situated and whether they are a public official or body or private person or company by any individual employee, agent or other person or body acting on our behalf in order to gain any commercial, contractual or regulatory advantage for us in a way which is unethical or in order to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual.

Our anti-bribery policy and procedures

Our anti-bribery policy reflects UK statutory requirements and should be regarded as the minimum acceptable standard of compliance for all our people. It addresses all inducements, rewards, corrupt payments, and bribes.

We confirm that:

We have conducted a review of our existing polices to ensure they meet the needs of the Act.

Overall responsibility for our anti-bribery and corruption policy lies with the Managing Director.
We have communicated our policy to all our people and associated people
Where appropriate, our people have received training on our anti-bribery and corruption policy and procedures. Previously, our people have received training by undertaking the on-line BVCA Anti Bribery and Corruption course. We expect further on-line training will be rolled out during the next 12 months as part of the CCL Compliance Training Solution that is shortly due to be implemented.
The Gifts and Entertainment Policy has been revised.
We have appropriate whistleblowing procedures in place to enable our people to report corruption in a safe and confidential manner.

Our gifts and entertainment policy

We do not believe that the giving and receiving of business gifts is appropriate or good commercial practice. Therefore, gifts will be dealt with as follows:

If any of our people is given a business gift of any sort by a business contact (e.g. customer, supplier etc. – actual or potential), they must disclose it to his/her manager.
Failure to disclose gifts is a disciplinary offence.

None of our people should give gifts to business contacts without the express permission of their manager.
Any employee who is any doubt about this policy should consult the Managing Director.
Where any gift, entertainment or discount to a value in excess of £100 is offered or received this must be advised to the Compliance Manager for entry in the Company’s Gifts and Entertainment Register.
Where there is any occurrence of gifts, entertainment or staff discount being offered consistently by the same donor within a three month period resulting in a cumulative value in excess of £100 being offered or received, this must be advised to the Compliance Manager for entry in the Company’s Gifts and Entertainment Register.
Where any gift, entertainment or discount to a value in excess of £200 is offered or received this must be authorised by either the Managing Director or any other Director. Directors are not permitted to authorise gifts or entertainment offered or received by them. Additionally, details of such gifts, entertainment or staff discount must be advised to the Compliance Manager for entry in the Company’s Gifts and Entertainment Register.

Where there is any occurrence of gifts, entertainment or discount being offered consistently by the same donor within a three month period resulting in a cumulative value in excess of £200 being offered or received, this must be authorised by either the Managing Director or any other Director. Directors are not permitted to authorise gifts or entertainment offered or received by them. Additionally, details of such gifts, entertainment or discount must be advised to the Compliance Manager for entry in the Company’s Gifts and Entertainment Register.
Where the value of the Gift or Entertainment received is above the value limit imposed by us, New Beginnings Consultation can offer it to all our people via a funded raffle and all proceeds will go a designated Charity.
Cash gifts or receipts from third parties are prohibited; the giving or receiving entertaining to a value in excess of £200 is not permitted unless with prior approval of the Managing Director or any other Director. Directors are not permitted to approve any gifts.

General monitoring of bribery and corruption will rely on vigilance by our managers of our people, and any sudden changes in their behaviour or attitudes. Suspected breaches of policy will be passed to the Managing Director and all reported allegations will be actively investigated.

All incidences will be included in Compliance Monitoring Reports, and key findings will be reported back to the Managing Director and to the Board of Directors.

Except for knowingly reporting false accusations, all our people may report allegations without fear of retaliation.