Anti Bribery, Corruption and Fraud Policy Statement
Epiphany has a clear policy on Bribery, corruption and fraud, and we support our employees to make decisions in line with our stated position. Our corporate conduct is based on our commitment to acting professionally, fairly and with integrity. Epiphany does not tolerate any form of bribery and corruption.
Company Policy
Epiphany values its reputation for ethical behaviour and for financial probity and reliability. It strives to serve its customers to the best of our teams ability, openly and honestly. Any involvement in bribery, corruption and fraud will also reflect adversely on its image and reputation. To maintain the trust of our customers and our excellent reputation, we:
- Setting out a clear anti-bribery, corruption and fraud policy.
- Provide training and guidance to all employees so they can recognise and avoid the use of bribery by themselves and others and avoid any activity that may be deemed as corrupt and/or fraudulent.
- Encouraging its employees to be vigilant and to report any suspicion of bribery, corruption or fraud, providing them with suitable channels of communication and ensuring sensitive information is treated appropriately.
- Rigorously investigating any such instances of alleged misconduct and assisting the police and other appropriate authorities in any resultant prosecution.
- Taking firm and vigorous action against any individual(s) involved in bribery, corruption or fraud.
- Epiphany does not engage in bribery or any form of unethical inducement or payment including facilitation payments and ‘kickbacks.’ All employees are required to avoid any activities that might lead to, or suggest, a conflict of interest with the business of the company. Employees must declare and keep a record of hospitality or gifts accepted or offered, which will be subject to managerial review.
The business prohibits 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 behalf of the business in order to gain any commercial, contractual or regulatory advantage for the business 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.
This policy prohibits any inducement which results in a personal gain or advantage to the recipient or any person or body associated with them, and which is intended to influence them to take action which may not be solely in the interests of the business or of the person or body employing them or whom they represent.
Responsibilities
The Epiphany directors are responsible for implementing this policy. If any instance of bribery, corruption or fraud is identified, we will take remedial steps immediately.
Employee responsibility:
The prevention, detection and reporting of bribery, corruption or fraud is the responsibility of all employees throughout the business. Suitable channels of communication by which employees or others can report any suspicion confidentially are available via management.
Training and communications:
We will communicate this policy and relevant guidance to all employees, through our established internal communication channels. We will also communicate this policy to our suppliers, contractors and business partners and wider stakeholders. Managers, employees and agents will receive relevant training on how to implement this policy in the scope of their employment with the business.
Raising Concerns and Seeking Guidance
Employees are encouraged to raise concerns about any instance of malpractice at the earliest possible stage by contacting Epiphany management.
Monitoring and review:
The Epiphany directors will review the implementation of this policy in respect of its suitability, adequacy and effectiveness and make improvements as appropriate. It will periodically review the results of this process within board meetings to assess the adequacy of the policy and disclose any material non-compliance.
Internal controls and audit:
Epiphany will establish feedback mechanisms to maintain accurate records – available for inspection - which properly and fairly document all financial transactions. Internal control systems will be subject to regular audits to provide assurance that they are effective in countering bribery, corruption and fraud.