Alexander Baker trading as @thatbakerface has zero tolerance for bribery and corruption. Controls are proportionate to a small owner-operated business and the generally limited bribery risk in its UK creative, event, media and technical work.
Prohibited conduct
The business, and anyone acting on its behalf, must not:
- offer, promise, give, request or accept a financial or other advantage intended to induce or reward improper conduct;
- bribe a public official or private person;
- use a third party to do something that would be prohibited if done directly;
- make a facilitation payment to speed up a routine official action;
- conceal a payment, gift, rebate, commission, conflict or other benefit; or
- retaliate against a person who raises a genuine concern in good faith.
Gifts and hospitality
Reasonable and proportionate hospitality may be accepted or provided where it is lawful, infrequent, connected with a legitimate business purpose and not intended to influence a decision improperly.
The following are not acceptable:
- cash or cash-equivalent gifts;
- secret commissions, kickbacks or personal rebates;
- lavish or repeated hospitality that could create an obligation;
- gifts or hospitality during a sensitive tender, award or dispute where they could influence the outcome; or
- anything that would be embarrassing or misleading if publicly disclosed.
Material, unusual or higher-risk gifts and hospitality will be declined or recorded with the reason for the decision.
Expenses, commissions and discounts
Payments must relate to genuine goods, services, expenses or agreed commercial arrangements. Invoices and records must describe the transaction accurately. Commissions, referral fees, discounts and rebates must be transparent, lawful and proportionate to the service provided.
Public officials and facilitation payments
Particular care will be taken in dealings with public officials, licensing bodies, inspectors, police, local authorities and publicly funded organisations. Facilitation payments are not permitted. If a payment is demanded where there is an immediate threat to personal safety, safety takes priority; the incident and payment must then be recorded and reported as soon as practicable.
Charitable and political activity
Any charitable support must be genuine and must not be used to secure an improper advantage. The business will not make a political contribution on behalf of a client or use business funds to disguise a personal or third-party political payment.
Conflicts of interest
Actual or potential conflicts that could affect, or appear to affect, impartial business judgement must be disclosed and managed. This may include personal relationships, undisclosed financial interests, referral arrangements or competing client obligations.
Suppliers, agents and subcontractors
- Checks will be proportionate to the role, value, location and risk of the engagement.
- Unusual payment routes, vague services, excessive commissions, cash demands or refusal to document an arrangement will be treated as warning signs.
- No person is authorised to offer or accept a bribe on behalf of the business.
- A relationship may be paused or ended where credible concerns are not resolved.
Record keeping
Quotes, invoices, payments, expenses and material gifts or hospitality will be recorded accurately enough to explain the business purpose. False, incomplete or misleading records are prohibited.
Reporting concerns
A concern should be raised promptly with Alexander Baker through the contact page. It is not necessary to prove bribery before reporting a genuine concern. Information will be handled as confidentially as reasonably possible.
Where criminal conduct is suspected, the business may report the matter to the police, Serious Fraud Office or another competent authority.
Breaches
A breach may result in refusal or termination of work, recovery of loss, removal of access, reporting to a client or authority, and legal action where appropriate.
Responsibility and review
Alexander Baker is responsible for setting the anti-bribery stance, considering material risks and applying proportionate checks. This policy will be reviewed if the business enters a new market, uses higher-risk intermediaries, handles significant procurement or receives a relevant concern.