Our Anti-Bribery and Corruption Policy

1. Policy Statement – Anti Bribery

Bribery is a criminal offence. We at MaiaHB do not, and will not, pay bribes or offer improper inducements to anyone for any purpose, nor do we or will we, accept bribes or improper inducements.

To use a third party as a conduit to channel bribes to others is a criminal offence. We do not, and will not, engage indirectly in or otherwise encourage bribery.

MaiaHB will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, in regards to our conduct both at home and abroad.

We are committed to the prevention, deterrence and detection of bribery. We have zero tolerance towards bribery. We aim to maintain anti-bribery compliance “business as usual”, rather than as a one-off exercise.

2. Scope of this Policy

This anti-bribery policy exists to set out the responsibilities of MaiaHB and those who work for us in regards to observing and upholding our zero-tolerance position on bribery and corruption.  This includes all personnel, including all levels and grades, those permanently employed, temporary agency staff, contractors, non-executives, agents, Members (including independent members), volunteers and consultants.

It also exists to act as a source of information and guidance for those working for MaiaHB.  It helps them recognise and deal with bribery and corruption issues, as well as understand their responsibilities.

3. MaiaHB’s Commitment

MaiaHB commits to:

• Setting out a clear anti-bribery policy and keeping it up to date
•  Making all employees aware of their responsibilities to adhere strictly to this policy at all times
• Training all employees so that they can recognise and avoid the use of bribery by themselves and others
• Encouraging its employees to be vigilant and to report any suspicions of bribery, providing them with suitable channels of communication and ensuring sensitive information is treated appropriately
• Rigorously investigating instances of alleged bribery and assisting police and other appropriate authorities in any resultant prosecution
• Taking firm and vigorous action against any individual(s) involved in bribery
• Provide information to all employees to report breaches and suspected breaches of this policy
• Include appropriate clauses in contracts to prevent bribery.

4. Definition of Bribery

Bribery is the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so as to induce or influence an action or decision.

A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.

Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.

Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes to any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the company’s compliance manager.

The Bribery Act 2010 (http://www.opsi.gov.uk/acts/acts2010/ukpga_20100023_en_1) makes it an offence to offer, promise or give a bribe.

5. What is and what is NOT acceptable

It is NOT acceptable to:

• Give, promise to give, or offer a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given.
• Give, promise to give, or offer a payment, gift or hospitality to a government official, agent or representative to “facilitate” or expedite a routine procedure.
• Accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them.
• Accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return.
• Retaliate against or threaten a person who has refused to commit a bribery offence or who has raised concerns under this policy.
• Engage in activity in breach of this policy.

Gifts and hospitality

MaiaHB accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements:

• It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits.
• It is not made with the suggestion that a return favour is expected.
• It is in compliance with local law.
• It is given in the name of the company, not in an individual’s name.
• It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).
• It is appropriate for the circumstances (e.g. giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).
• It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.
• It is given/received openly, not secretly.
• It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.
• It is not above a certain excessive value, as pre-determined by the company’s compliance manager (usually not in excess of £100).
• It is not offer to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s compliance manager

Facilitation Payments and Kickbacks

MaiaHB does not accept and will not make any form of facilitation payments of any nature.  Facilitation payments are unofficial payments made to public officials in order to secure or expedite actions.  This is a form of bribery and is illegal and will not be tolerated at MaiaHB.

MaiaHB does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage.

Political Contributions

MaiaHB will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage.

6. Employee Responsibility

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for MaiaHB or under its control.  All staff are required to avoid activity that breaches this policy.

 You must:

• ensure that you read, understand and comply with this policy and with any training or other anti-bribery and corruption information you are given.
• Raise concerns as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. As well as the possibility of civil and criminal prosecution, staff that breach this policy will face disciplinary action, which could result in dismissal for gross misconduct.

As well as the possibility of civil and criminal prosecution, staff that breach this policy will face disciplinary action, which could result in dismissal for gross misconduct.

7. How to Raise a Concern

If you suspect that there is an instance of bribery or corrupt activities occurring in relation to MaiaHB , you should raise your concerns at as early a stage as possible.  If you’re uncertain about whether a certain action or behaviour can be considered bribery or corruption, you should speak to your line manager, the compliance manager, the director, or the CEO.

Concerns can be anonymous. In the event that an incident of bribery, corruption, or wrongdoing is reported, we will act as soon as possible to evaluate the situation. We have clearly defined procedures for investigating fraud, misconduct and non-compliance issues and these will be followed in any investigation of this kind. This is easier and quicker if concerns raised are not anonymous.

8. Protection

Staff who refuse to accept or offer a bribe, or those who raise concerns or report wrongdoing can understandably be worried about the repercussions. We aim to encourage openness and will support anyone who raises a genuine concern in good faith under this policy, even if they turn out to be mistaken.  We are committed to ensuring nobody suffers detrimental treatment through refusing to take part in bribery or corruption or because of reporting a concern in good faith. 

9. Training and Communication

MaiaHB will provide training on this policy as part of the induction process for all new employees.  Employees will also receive regular, relevant training on how to adhere to this policy, and will be asked annually to formally accept that they will comply with this policy.

MAiaHB’s anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third parties at the outset of business relations, and as appropriate thereafter.

10. Other

Any need for improvements will be applied as soon as possible.  Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the compliance manager.