Anti Bribery and Corruption Policy

1. Policy Statement

SME Innovation Network is committed to conducting all its activities with integrity and transparency. Bribery and corruption undermine trust, damage reputation, and hinder fair competition. We have a zero-tolerance approach to bribery and corruption and are dedicated to ensuring compliance with applicable anti-bribery laws, including the UK Bribery Act 2010.

2. Scope

This policy applies to all employees, directors, contractors, suppliers, and business partners associated with SME Innovation Network. It covers all operations and activities globally.

3. Definitions

• Bribery: Offering, promising, giving, accepting, or soliciting anything of value as an inducement for an action that is illegal, unethical, or a breach of trust.
• Corruption: Abuse of entrusted power or position for private gain.

4. Policy Guidelines

a. Prohibition of Bribery and Corruption:

• No employee or associated party may offer, promise, give, request, accept, or agree to receive any form of bribe or engage in corrupt practices.
• All interactions and transactions must be transparent, ethical, and lawful.

b. Gifts, Hospitality, and Expenses:

• Gifts and hospitality must be modest, appropriate, and transparent, and must never influence or appear to influence decision-making.
• Prior approval from senior management is required for significant gifts or hospitality.
• Accurate records of all gifts, hospitality, and expenses must be maintained.

c. Facilitation Payments:

• Facilitation payments, regardless of size, are strictly prohibited.

d. Charitable Contributions and Sponsorships:

• Charitable contributions and sponsorships must never be used as a vehicle for bribery or corruption.
• Due diligence must be conducted before agreeing to charitable or sponsorship payments.

5. Record-Keeping:

SME Innovation Network will maintain clear, accurate, and detailed records of all transactions, gifts, hospitality, and expenses to ensure transparency and compliance.

6. Reporting and Whistleblowing:

Employees and associated parties are encouraged to report any suspected bribery or corruption immediately. Reports can be made confidentially without fear of retaliation. SME Innovation Network will thoroughly investigate all reported concerns.

7. Training and Awareness:

Regular training and awareness programs will be provided to ensure understanding and compliance with this policy.

8. Consequences of Non-Compliance:

Any breach of this policy may result in disciplinary action, up to and including termination of employment or contractual relationship, and may be reported to relevant authorities.

9. Monitoring and Review:

This policy will be reviewed regularly and updated as necessary to maintain effectiveness and compliance with relevant legislation.

10. Responsibility:

Overall responsibility for this policy lies with senior management, who are responsible for ensuring compliance and effectiveness across the organisation.

SME Innovation Network is fully committed to promoting integrity, transparency, and compliance. All stakeholders are expected to uphold these principles and adhere strictly to this policy.