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Bribery Policy


Bribery Policy Mission Statement


TK Waterproofing Solutions Ltd (the Company) is committed to conducting business ethically and with integrity, to ensure that the business can be conducted in a free and fair market.  Every individual and organisation that acts on the Company’s behalf, or represents TK Waterproofing Solutions Ltd, is responsible for ensuring that this principle is upheld, and the policy is implemented so that TK Waterproofing Solutions Ltd, conducts all business in an honest and professional manner in line with The Bribery Act 2010.



This policy applies to employees, workers, or any individual or organisation, that conducts Company business or represents the Company in any capacity.


Compliance Policy, Practices and Procedures

TK Waterproofing Solutions Ltd has a zero-tolerance policy towards any form of bribery. Whether this bribery takes the form of a direct or indirect financial payment, or other reward, or advantage, to encourage an individual or organisation to perform their functions or activities improperly, or as a reward for having already performed their functions or activities improperly.


Any individual or organisation acting on behalf of TK Waterproofing Solutions Ltd is strictly prohibited from offering, promising, giving, requesting, agreeing to receive, or accepting any bribes or backhanders.  Any breach of this policy by an employee will be treated as gross misconduct, and may result in their summary dismissal. Any breach of this policy by a third party or sub-contractor, acting for the Company will result in an immediate termination of their contractual arrangements.


Employees and other individuals or organisations acting for TK Waterproofing Solutions Ltd, should be aware that bribery is a criminal offence which may result in up to 10 years’ imprisonment, and an unlimited fine for both the individual and Company.


It is an offence under section 7 for a ‘relevant commercial organisation’ such as the company, to fail to prevent bribery.  In this context it is liable if a person associated with it (a director, an employee), commits an act of bribery whether that person is prosecuted or not.


It is however, a defence to any such criminal allegation to show, on balance of probabilities, that the organisation nevertheless had adequate procedures in place, to prevent persons associated with it from bribing.


In order to prevent the unwitting engagement in behaviour, which might raise the suspicion of bribery, and prevent any associated person purporting to act on its behalf in a manner that brings suspicion on the directors and employees, the following measures have been adopted as appropriate and proportionate to the risks it faces.  They will be enforced by their dissemination and disciplinary measures.  Any resources that are required to implement any compliance measures are to be made available.



The responsibility for compliance of this policy rests with the Company Directors, who will exercise oversight, make assessments of risk, deal with decisions where potential for bribery exists, receive and investigate reports of bribery, and supervise the measures put in place to prevent bribery.


The daily overall responsibility for the compliance with the Bribery Act, and the implementation of the policy rests with the Contracts Director and the Finance Director.  They are to be consulted on any matter where the possibility of unlawful acts could arise.


The directors and employees shall report any attempt at bribery which comes to their attention, whether it consists of an approach to one of them, or an act done by an associated third party.  In the first instance the report should be made to the Contracts Director, or the Finance Director.


Under no circumstances should a person who reports a suspicion of bribery be subject to victimisation for making a bona fide report, whether or not the suspicion turns out to be justified.


Assessment of Risk

The directors are governed by a strict code of conduct and the employees act upon instructions and are chosen for their integrity as well as ability.  As such the general assessment of the risk of committing an offence under the Act is very low.


The risk of falling foul of section 6 offence, of bribing a foreign official or of extra-territorial

offences do not arise.



  • In relation to occasions in which hospitality is offered, or accepted by directors or employees, issues may arise as to the line between a proper public relations exercise,

and intention to induce improper performance of a relevant function;


  • In relation to awarding of contracts for services, the Company has provisions for competitive tendering in place.  However, as an additional requirement and as a

requirement in awarding contracts which are not required to go out to tender, an

issue of bribery may arise.


  • In relation to charitable and political donations, care must be exercised to avoid the suggestion of soliciting favours.


  • The assessment of the Company’s exposure to external and internal risks of bribery

will be assessed annually.



In relation to hospitality, promotional expenditure which seeks to improve the image of the Company, to establish cordial and professional relationships, and to maintain them is not unlawful if it is reasonable and proportional.



As a general rule the Company finds it acceptable for its staff to receive small gifts from grateful clients, suppliers etc.  However, the Company does not condone under any circumstances, any inducements leading to corruption, bribery, or behaviour detrimental to the business or its reputation.


Any event which is to be offered to a client or prospective client, the Contracts Director will have to be supplied with information.  This will include the cost and nature of the hospitality, the name and details of the person to be entertained, and the purpose of the event.  He will be required to approve the event, or make suggestions for modifying it.


In the event that a director or employee is invited to an event, a similar procedure should be followed.


Any individual who is given a gift from an existing or potential client, customer, supplier etc. must inform the Contracts Director to ensure that an assessment can be made as to the intentions behind the giving of the gift. If the gift has been given with the statement that it is a gesture of goodwill and appreciation, and is not of substantial value, the individual may be permitted, at the Company’s discretion to keep the gift or to share it with colleagues. However, if it is felt that the gift is unclear, it may constitute a bribe, or there is a suspicion that it has been given with the intention of influencing the Company’s decision in some way, and/or there is a conflict of interest, and/or it appears to be of excessive value, the individual will be asked to return the gift to the sender advising them of the Company’s policy relating to gifts and request that this is respected.


This also applies to gifts and/or services offered indirectly.  If an individual is unsure in any way as to what constitutes a gift, please raise this immediately with the Contracts Director.


For clarity, the following are examples of situations that may arise;

Unlikely to be acceptable                          May be acceptable

* Accepting football tickets from a client who wishes to be      * Accepting football tickets from a client following the 

 considered for a discount                                           completion of a successful project when no contract

                                                                        discussions are ongoing

* Accepting chocolates from a supplier in the middle of a       * Accepting chocolates from a supplier with festive good

  review of the current supplier agreement                         wishes at the end of the calendar year


Any employee found to have accepted gifts without the appropriate authorisation will be liable to disciplinary action. Deliberate taking of bribes will be treated as an act of gross misconduct.


Any third party or sub-contractor acting for the Company found to have accepted gifts without the appropriate authorisation, may have their contractual arrangements terminated.


Contracts with Clients

No fees over and above proper professional fees agreed in advance for professional work done may be accepted.  No payment may be made to the client for the award of a contract for services.


Third Parties

A Third party should be engaged to act on behalf of TK Waterproofing Solutions Limited in a manner consistent with this policy.  The terms of engagement should be written down and refer to this policy. 


Due diligence checks carried out on prospective contractors ought to include, where appropriate, an assessment of their ethical conduct.


Charitable and Political Donations

Donations of a charitable or political nature must be approved by a full director’s meeting, and be subject to a prior audit to ensure that there can be no suspicion that any advantage could be thought to accrue to the Company, or any of its directors or employees.



Notification of Concerns

If you become aware of any conduct which you believe may be in breach of this policy and/or the associated policies and procedures, you should raise your concerns immediately with the Contracts Director, under the Public Interest Disclosure procedure. Whilst you should report any concerns, in particular the following should be reported:


  • Any suspected or actual attempts to bribe or provide backhanders;

  • Any requests for unusual payments and/or cash payments;

  • Unusual or unsubstantiated expenses;

  • Failure to follow normal financial practices, such as a lack of appropriate invoices;

  • Business relationships with close family members, personal friends etc.

  • Business activities in countries or with individuals who have a history of corruption.


In line with the Public Interest Disclosure procedure, if you report your concerns in good faith you will be supported and will not be subjected to any detriment as a result of raising your concerns. Failure to raise your concerns will be considered a breach of trust, and dealt with under the disciplinary procedure. Should any employee raise concerns which are subsequently found to be in any way malicious, this will be dealt with under the Company’s disciplinary process and may be treated as an act of gross misconduct.


The Company appreciates that the risk of bribery may change over the course of time and therefore the Contracts Director will take responsibility for reviewing this policy and its implementation on a regular basis.



A copy of this policy will be given to all employees of the company and will be included in the Staff Handbook.  Reference will be made to it in documents provided to clients and contracts with suppliers.



Where deemed necessary, staff employed by TK Waterproofing Solutions Ltd and the directors themselves, will be required to undergo regular training in terms of the Bribery Act, and the requirements described in this document.


Any director or member of staff should be able to approach the Contracts Director in absolute confidence, in order to receive advice as to their conduct, or to report a matter of concern which relates to bribery.


This policy will be reviewed annually for its continued effectiveness and suitability.





Colin Taylor



April 2021

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