The purpose of this policy is to set out our rules on the giving and receiving of gifts and corporate hospitality in order to protect our reputation and ensure that we operate both lawfully and ethically.

This policy applies to all our employees.

Offering Gifts

We support the practice of offering modest non-cash gifts to business partners where appropriate for marketing purposes, as long as the gift is occasional and not regular or repeated, or other purposes such as expressing thanks or making a goodwill gesture. For example, employees may offer promotional material such as pens and calendars for marketing purposes or send a small token gift to a business partner as a Christmas gift.

If employees wish to offer a gift worth more than £20 you must obtain prior approval from the Managing Director who will decide if the proposed gift is legitimate, proportionate and reasonable.

Employees should never offer:

• cash gifts;
• any sort of gift where the intention is to influence the recipient’s judgment; or
• any sort of gift where you know that the recipient is not allowed to receive it.

Accepting Gifts

Employees are allowed to accept token gifts from business partners or potential business partners where this constitutes legitimate and reasonable marketing or where it is a legitimate goodwill gesture. For example, you can accept promotional items such as desk calendars or pens.

Employees should never accept:

• cash gifts;
• gifts which are extravagant or out of proportion with the value of the business relationship;
• repeated/regular gifts from the same donor;
• any sort of gift where your judgement might reasonably be thought to be at risk of influence as a result of the gift. For example, a gift from a potential business partner shortly before you make a decision over whether or not to award them a contract; or
• any sort of gift which might reasonably bring the business into disrepute or be contrary to terms or the spirit of our equal opportunities/dignity at work policy.

If employees are offered any gift in circumstances that makes you concerned or uncomfortable then you should raise this with the Managing Director. It is our policy and your responsibility to act ethically at all times.

If any unauthorised gift is offered to you then you should decline it politely explaining that our policy does not permit you to accept it, unless to do so would be embarrassing or insulting in which case you should accept the gift. Flowflex will then write to the donor of the gift explaining our policy and return the item.

Gifts And Overseas Travel

If you are travelling overseas on business to an area where gifts are an important part of business culture then you will be allowed and expected to participate in gift giving and receiving but this still needs to be proportionate and reasonable from a UK perspective.

Corporate Hospitality And Entertainment

Our policy is to participate in corporate hospitality and entertainment where this will promote good relationships with our business partners

In addition, working lunches with business partners are appropriate, as long as they are reasonable and modest in line with our expenses policy.

However, corporate hospitality and entertainment, including attendance at dinners or sporting events, should not be offered or accepted if:

• it is lavish or extravagant;
• it is on a scale which is disproportionate to the legitimate business value of the relationship;
• an employee is offering it with the intention of influencing the recipient’s judgment or when you know they are not permitted to accept it;
• an employee is offered it in circumstances when acceptance would influence your business judgment or put you in a difficult position;
• if it would infringe our expenses policy; or
• if it might reasonably bring the business into disrepute or contravene the terms or the spirit of our equal opportunities/dignity at work policy.

If you unsure as to whether a particular invitation is appropriate, you should seek guidance from the Managing Director.

Facilitation Payments And Kickbacks

We do not make, and will not accept, facilitation payments or ‘kickbacks’ of any kind. Facilitation payments are typically small, unofficial payments and kickbacks are typically payments made in return for a business favour or advantage. All employees must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.

Donations

We do not make contributions of any kind to political parties. No charitable donations will be made for the purpose of gaining any commercial advantage.

Raising Concerns

Employees will be encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. No employee will suffer any detriment as a result of raising genuine concerns about bribery, even if they turn out to be mistaken.

Monitoring

The effectiveness of this policy will be regularly reviewed by the company.