Ethics & Anti-bribery Policy

Updated: April 2018

Isode’s policy is to uphold all laws relevant to countering bribery and corruption in all the markets in which we operate. Under UK law, bribery and corruption is punishable for individuals by up to 10 years imprisonment. If Isode is f ound to have taken part in the corruption or lacks adequate procedures to prevent bribery Isode could face an unlimited fine and be excluded from Government contracts.
We have a zero tolerance approach to acts of bribery and corruption by our employees or by those acting on our behalf, such as our partners. Isode does not condone:

Making contributions of any kind with the purpose of gaining commercial advantage.
Providing gifts or hospitality with the intention of persuading anyone to act improperly.
Making, or accepting, facilitation payments or “kickbacks” of any kind.

Isode recognises that practices vary between the different countries in which we or our partners do business and that what is acceptable in one country may not be in another. This policy is not meant to prohibit giving and receiving promotional gifts of low value, or normal hospitality practices providing they are customary in a particular market, are proportionate and are properly recorded.
We regularly monitor and review our compliance with anti-bribery requirements. If our partners are found to be in breach of anti-bribery legislation appropriate action will be taken by Isode which may include termination of our partnership with the offending company or its subsidiary.
Isode has a strict anti-bribery and corruption policy in line with the Bribery Act (2010). A bribe is defined as:
Giving someone a financial or other advantage to encourage that person to perform their functions or activities improperly or to reward that person for having already done so.

The Act provides for four bribery offences:

  • Bribing: the offering, promising or giving of an advantage.
  • Being bribed: requesting, agreeing to receive or accepting an advantage.
  • Bribing a foreign public official.
  • The “corporate offence” where a commercial organisation fails to prevent persons performing services on its behalf from committing bribery.

If you bribe (or attempt to bribe) another person, intending either to obtain or retain business for Isode, or to obtain or retain an advantage in the conduct of the company’s business this will be considered gross misconduct. Similarly accepting or allowing another person to accept a bribe will be considered gross misconduct. In these circumstances you will be subject to formal investigation under Isode’s disciplinary procedures, and disciplinary action up to and including dismissal may be applied.
The Act does contains a defence under which the company can minimise or escape liability for corporate bribery if it can show that it had in place “adequate procedures” designed to prevent those persons performing services on its behalf from committing bribery. The Guidance outlines 6 key compliance areas:

  1. Proportionate procedures: An organisation should put procedures in place proportionate to the bribery risks that are faced dependant on the nature of the organisation. The procedures should be clear, practical, accessible, effectively implemented and enforced.
  2. Top level commitment: Top management must be committed to preventing bribery through both their actions and effective communications.
  3. Risk assessment: The organisation should regularly assess its exposure to potential external and internal risks of bribery.
  4. Due diligence: There must be effective procedures in place that take a proportionate and risk based approach in respect of those involved in the organisation or carrying services out on behalf of the organisation.
  5. Communication: The organisation’s policy on bribery must be communicated to all employees, and to all those carrying out services on its behalf. Additional training or awareness raising may be appropriate or proportionate depending on the size and type of your business
  6. Monitoring and review: As the business changes over time, there should be an ongoing monitoring process of all bribery procedures and action taken to update these as appropriate.