Anti-Bribery & Anti-Corruption policies and procedures
Purpose & scope
Harneys Anti-Bribery and Anti-Corruption Policies and Procedures set out the policies and procedures for identifying, preventing and avoiding corruption and bribery in the Harney Westwood & Riegels group (Harneys).
The policies and procedures apply to all persons involved in Harneys business, including people working on Harney’s behalf, partners, shareholders, officers and directors (collectively referred to as employees).
It is the policy of Harneys to conduct all its business in an honest and ethical manner. Harneys takes a zero tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all business dealings and relationships wherever Harneys operates.
Harneys and its employees (or someone on the employee’s behalf) must not engage in any activity that might lead to a breach of its Anti-Bribery and Anti-Corruption Policies and Procedures.
An Anti-Bribery Committee has been established which is responsible for implementing the requirements of the policies and procedures, including considering applications and investigating reports, monitoring effectiveness and arranging adequate and regular training.
Payments, gifts & hospitality
Harneys does not make, and will not accept, facilitation payments or ‘kickbacks’ of any kind.
Harneys and its employees (or someone on the employee’s behalf) must not give, promise to give, or offer, a payment, gift or hospitality (except normal and appropriate gifts or hospitality as set out in the policies and procedures) (i) with the expectation or hope that a business advantage will be received, or (ii) to reward a business advantage already given; or (iii) to a government official, agent or representative to ‘facilitate’ or expedite a routine procedure.
Harneys and its employees (or someone on the employee’s behalf) must not accept a payment, gift or hospitality (except normal and appropriate gifts or hospitality as set out in the policies and procedures) from a third party that an employee knows or suspects is offered or provided with an expectation that a business advantage will be provided by Harneys in return.
Harneys reserves the right to review each situation as it arises and may approve a specific gift or hospitality upon application to the Anti-Bribery Committee in accordance with the policies and procedures.
Political & charitable donations
Harneys does not make contributions to political parties. Harneys only makes charitable donations that are legal and ethical under local laws and practices. Harneys has Corporate Social Responsibility Committees in each office which receive, review and decide upon all donation and sponsorship requests in accordance with its CSR policy, priorities and established practice.
Reporting & whistleblower protection
Employees must adhere to the reporting and disclosure requirements set out in the policies and procedures. Harneys and its employees (or someone on the employee’s behalf) must not threaten or retaliate against another employee who has refused to commit a bribery offence or who has raised concerns under the policies and procedures.