Anti-Bribery and Corruption Statement
Introduction
The Stewart Group Limited and its subsidiaries (the Stewart Group) recognises that bribery and corruption has a detrimental effect on communities wherever they occur. Bribery is a criminal offence in most countries in which the Stewart Group operates, and corrupt acts expose the Stewart Group and its employees to the risk of prosecution, fines and imprisonment, as well as endangering the Stewart Group’s reputation. It is the Stewart Group’s policy to comply with all anti-bribery and corruption laws of the UK or any nation in which we do business.
With the introduction of the UK Bribery Act 2010, the Stewart Group has taken steps to introduce “adequate procedures” which are rigorously applied and reviewed to ensure that we are fully compliant with the provisions of the Bribery Act.
It is the Stewart Group’s policy to maintain the highest level of ethical standards in the conduct of its business affairs and the Stewart Group has a zero tolerance of bribery and corruption. This policy has been adopted by the Stewart Group’s board and is to be communicated to everyone involved in our business to ensure their commitment to it.
Scope
The Stewart Group’s zero tolerance of bribery and corruption applies to all officers, directors and employees as well as any agents, contractors, representatives or other parties acting on behalf of the Stewart Group or any subsidiary, of which the Company has effective control, in any country that we operate. The Stewart Group also encourages the application of a zero tolerance policy on bribery and corruption in any subsidiary in which we do not have a controlling interest.
The Stewart Group expects our business partners, suppliers and contractors to act with integrity and without thought or actions involving bribery and/or corruption and will, where appropriate, include clauses to this effect in relevant contracts.
The Statement
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The Stewart Group 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 the Stewart Group's behalf in order to gain any commercial, contractual or regulatory advantage for the Stewart Group in a way which is unethical or in order to gain any personal advantage, financial or otherwise, for the individual or anyone connected with the individual. |
This 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 Stewart Group or of the person or body employing them or whom they represent.
The Stewart Group in its ongoing efforts to keep its high ethical standards and with a view to upholding its position against any form of bribery, has implemented:
- A clear Anti-Bribery and Corruption Policy with detailed guidance and procedures covering matters such as facilitation payments, gifts and hospitality, political donations and whistle blowing.
- Training for all employees so that they can recognise and avoid the use of bribery by themselves and others.
- Suitable channels of communication which encourage our employees to be vigilant and to report any suspicion of bribery and ensure sensitive information is treated appropriately.
- Rigorous investigating procedures for instances of alleged bribery and assisting the police and other appropriate authorities in any resultant prosecution.
- Procedures for taking firm and vigorous action against any individuals involved in bribery.
Expectations of the Stewart Group and Staff
The prevention, detection and reporting of bribery and corruption is the responsibility of all employees throughout the Stewart Group. Suitable channels of communication by which employees or others can report confidentially any suspicion of bribery will be maintained. Details of which can be found in the Stewart Group’s Anti-Bribery and Corruption Policy.
The Chairman has lead responsibility for policy implementation within the Stewart Group and this policy is signed by the Chairman to demonstrate the Board’s commitment.
William M Budge
Chairman
The Stewart Group Limited
Issue No: 1 dated 30th June 2011