{"id":141780,"date":"2024-01-12T10:17:26","date_gmt":"2024-01-12T10:17:26","guid":{"rendered":"https:\/\/round-lake.dustinice.workers.dev:443\/https\/launch.iot-now.com\/?page_id=141780"},"modified":"2024-01-12T11:26:20","modified_gmt":"2024-01-12T11:26:20","slug":"anti-bribery-policy","status":"publish","type":"page","link":"https:\/\/round-lake.dustinice.workers.dev:443\/https\/iot-now.com\/anti-bribery-policy\/","title":{"rendered":"Anti-Bribery Policy"},"content":{"rendered":"\n<p class=\"wp-block-paragraph\">WeKnow Media Ltd, the owners of IoT Now, is committed to carrying out its business and relationships professionally and with integrity and ensuring compliance with the requirements of the Bribery Act 2010. WeKnow Media is committed to the prevention, detection and deterrence of bribery. We take a zero-tolerance approach to acts of bribery and any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We may also look to prosecute those found to have been involved in acts of bribery. Any non-employee who breaches this policy may also have action taken against them.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">Read our full policy below.<\/p>\n\n\n\n<hr class=\"wp-block-separator is-style-wide\"\/>\n\n\n\n<h3 class=\"wp-block-heading\">WeKnow Media\u2019s commitment to the Policy<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">WeKnow Media is committed to carrying out its business and relationships<br>professionally and with integrity and ensuring compliance with the requirements of<br>the Bribery Act 2010.<br>WeKnow Media is committed to the prevention, detection and deterrence of bribery.<br>We take a zero-tolerance approach to acts of bribery and any employee who<br>breaches this policy will face disciplinary action, which could result in dismissal for<br>gross misconduct. We may also look to prosecute those found to have been involved<br>in acts of bribery. Any non-employee who breaches this policy may also have action<br>taken against them.<\/p>\n\n\n\n<h3 class=\"wp-block-heading\">What are the aims and requirements of the legislation?<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">To ensure that WeKnow Media conducts its business to the highest legal and ethical<br>standards. WeKnow Media will not be party to corruption or bribery in any form. All of<br>us must work together to ensure that it is untainted by bribery or corruption. This<br>policy is a crucial element of that effort. Where Bribery is found to occur, in any form,<br>it will be dealt with rigorously in a controlled manner in accordance with the principles<br>in the Bribery Act policy. It will be investigated fully, and offenders will be prosecuted<br>where appropriate including, Members, employees, contractors and external<br>partners.<\/p>\n\n\n\n<h3 class=\"wp-block-heading\">Who is governed by this Policy?<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">The Bribery Act policy covers everyone working for us, or on our behalf, in any<br>capacity including all permanent employees, temporary agency employees,<br>contractors, volunteers, interns, third-party representatives, consultants or any other<br>person associated with WeKnow Media.<\/p>\n\n\n\n<h3 class=\"wp-block-heading\">Contents<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\"><a href=\"#bribery-act\">The Bribery Act 2010 including the Aim and Scope of this policy<br><\/a><a href=\"#adequate-procedures\">What are adequate procedures?<br><\/a><a href=\"#principles\">What are the principles?<\/a><br><a href=\"#golden-rules\">Golden Rules<br><\/a><a href=\"#employee-responsibilities\">Employee Responsibilities<br><\/a><a href=\"#reporting-concern\">Reporting a concern<br><\/a><a href=\"#support-guidance\">Further support and guidance<\/a><\/p>\n\n\n\n<h2 class=\"wp-block-heading\" id=\"bribery-act\"><strong>The Bribery Act 2010<\/strong><\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">Bribery is offering, promising, giving or accepting any financial or other advantage, to<br>induce the recipient or any other person to act improperly in the performance of their<br>functions, or to reward them for acting improperly, or where the recipient would act<br>improperly by accepting the advantage.<br>An advantage includes money, gifts, loans, fees, hospitality, services, discounts, the<br>award of a contract or any other advantage or benefit.<br>A person acts improperly where they act in breach of an expectation of good faith,<br>impartiality, or trust.<br>Bribery is a serious criminal offence with a maximum sentence of ten years\u2019<br>imprisonment and\/or an unlimited fine.<br>WeKnow Media can be held criminally responsible for failing to prevent bribery if a<br>person associated with the company bribes another person unless WeKnow Media<br>has in place adequate procedures to prevent this.<\/p>\n\n\n\n<h4 class=\"wp-block-heading\">The aim of this policy<\/h4>\n\n\n\n<p class=\"wp-block-paragraph\">This policy provides a framework to allow those working for WeKnow Media, or on its<br>behalf, to understand and put into place arrangements to prevent bribery. It<br>demonstrates that WeKnow Media has implemented adequate procedures to<br>prevent bribery by persons associated with the company. It will work with related<br>policies, and other documents, to identify and report when this policy is breached<br>and aims to ensure that everyone:<\/p>\n\n\n\n<ul class=\"wp-block-list\"><li>always acts with integrity and protects the WeKnow Media\u2019s resources which they are responsible for; and<\/li><li>keeps to the spirit, and letter, of the laws and regulations that cover our work<\/li><\/ul>\n\n\n\n<h4 class=\"wp-block-heading\">Scope of this policy<\/h4>\n\n\n\n<p class=\"wp-block-paragraph\">This policy applies to all our activities. All levels of WeKnow Media\u2019s personnel are<br>responsible for controlling the risk of bribery. We encourage suppliers and other<br>organisations we work with to adopt policies that are consistent with the principles<br>set out in this policy.<br>The Anti-Bribery policy applies to and covers everyone working for us, or on our<br>behalf, all permanent employees, temporary agency, contractors, volunteers and<br>consultants. Everyone, at all levels of the council, has a responsibility to control the<br>risk of bribery occurring.<\/p>\n\n\n\n<h3 class=\"wp-block-heading\" id=\"adequate-procedures\">What are \u201cadequate procedures\u201d<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">For WeKnow Media to show that it takes the Bribery Act seriously, we need to show<br>we have adequate procedures in place designed to prevent bribery. Our procedures<br>need to be in proportion to the level of risk of bribery in our organisation. WeKnow<br>Media is committed to the six principles for bribery prevention issued by the Ministry<br>of Justice.<\/p>\n\n\n\n<h3 class=\"wp-block-heading\" id=\"principles\">What are the principles?<\/h3>\n\n\n\n<ol class=\"wp-block-list\"><li><strong>Proportionate procedures<br><\/strong>WeKnow Media\u2019s procedures to prevent bribery by a person associated with it are<br>proportionate to the bribery risks it faces and to the nature, scale and complexity of<br>the Council\u2019s activities. The procedures are clear, practical, accessible and<br>effectively put into place and enforced.<\/li><li><strong>Commitment at the top levels of our organisation<br><\/strong>Our Senior Leadership Team are committed to preventing bribery by the people<br>associated with us. They help create a culture in our organisation where bribery is<br>never acceptable.<\/li><li><strong>Risk assessment<br><\/strong>We assess how and to what extent we will be exposed to potential risks of bribery as<br>part of a wider fraud risk assessment. We keep a record of the assessment, which<br>includes financial risks and also other risks such as damage to our reputation.<\/li><li><strong>Due diligence<br><\/strong>We apply due diligence procedures in relation to people who provide services for or<br>on behalf of our organisation to reduce the risks of bribery.<\/li><li><strong>Communication<br><\/strong>We aim to make sure that our policies and procedures to prevent bribery are<br>understood throughout our organisation. We do this through communication inside<br>and outside of our organisation.<\/li><li><strong>Monitoring and review<br><\/strong>We monitor and review the procedures designed to prevent bribery and make<br>improvements where they are needed. We are committed to putting these principles<br>into place as, should we be found guilty of an offence under section 7 of the Act, we<br>can be fined an unlimited amount.<\/li><li><strong>Facilitation payments<br><\/strong>Facilitation payments are unofficial payments made to WeKnow Media in order to get<br>the company to take certain actions or take actions more quickly. Facilitation<br>payments are illegal under the Bribery Act 2010 and we will not tolerate them.<\/li><li><strong>Gifts and hospitality<br><\/strong>Personnel associated with WeKnow Media should not accept anything with more<br>than a token value (examples of things that are of token value include bottles of<br>wine, boxes of chocolates, flowers, pens, calendars and diaries), with a minimal<br>value. Any Gifts and Hospitality offered that sits logically outside of these<br>parameters, should be reported to managers who can advise whether any further,<br>formal reporting, needs to happen.<\/li><li><strong>Contracts and failure to prevent bribery<br><\/strong>Persons and or companies are to be excluded from consideration of supplying or<br>working with WeKnow Media, if they have previously been convicted of a corruption<br>offence.<\/li><\/ol>\n\n\n\n<h3 class=\"wp-block-heading\" id=\"golden-rules\">Golden Rules<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">We will not tolerate bribery and those covered by the policy must not:<\/p>\n\n\n\n<ul class=\"wp-block-list\"><li>give, promise to give, or offer a payment, a gift or hospitality with the expectation or hope that they will receive a business advantage, or to reward a business advantage that they have already been given<\/li><li>give, promise to give, or offer a payment, a gift or hospitality to speed up a routine procedure<\/li><li>accept a payment from another person or organisation if they know or suspect that it is offered with the expectation that it will give them a business advantage<\/li><li>accept a gift or hospitality from another person or organisation if they know or suspect that it is offered or provided with an expectation that they will provide a business advantage in return<\/li><li>act against or threaten a person who has refused to commit a bribery offence or who has raised concerns under this policy; or<\/li><li>take part in activities that break this policy<\/li><\/ul>\n\n\n\n<p class=\"wp-block-paragraph\"><strong>We are committed to:<\/strong><\/p>\n\n\n\n<ul class=\"wp-block-list\"><li>setting out a clear Anti-Bribery policy and keeping it up to date<\/li><li>making all employees aware of their responsibility to always keep to this policy<\/li><li>encouraging our employees to be aware and to report any suspicions of bribery<\/li><li>providing our employees with information on suitable ways of telling us about their suspicions and making sure we treat sensitive information appropriately<\/li><li>investigating alleged bribery and helping the police and other authorities in any prosecution that happens because of the alleged bribery<\/li><li>taking firm action against any people involved in bribery<\/li><\/ul>\n\n\n\n<h3 class=\"wp-block-heading\" id=\"employee-responsibilities\">Employee Responsibilities<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">All the people who work for us or are under our control are responsible for<br>preventing, detecting and reporting bribery and other forms of corruption. All<br>employees must avoid activities that break this policy and must:<\/p>\n\n\n\n<ul class=\"wp-block-list\"><li>make sure they read, understand and keep to this policy; and<\/li><li>tell us as soon as possible if they believe or suspect that someone has broken this policy, or may break this policy in the future <\/li><\/ul>\n\n\n\n<p class=\"wp-block-paragraph\">Anyone covered by the policy found to break it will face disciplinary action, potentially<br>leading to dismissal for gross misconduct and\/or may also face civil and\/or criminal<br>prosecution.<\/p>\n\n\n\n<h3 class=\"wp-block-heading\" id=\"reporting-concern\">Reporting a concern<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">We all have a responsibility to help detect, prevent and report instances of bribery. If<br>anyone has a concern about suspected bribery or corruption, they should speak up.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">The sooner they act, the sooner the situation can be dealt with. There are several<br>ways of informing about any concerns including talking to a line manager first or one<br>going directly to the Managing Director.<br>Those reporting concerns do not have to give us their name. Upon receiving a report<br>about an incident of bribery, corruption or wrongdoing, action will be taken as soon<br>as possible to assess the situation. In some circumstances, we will have to consider<br>reporting the matter to the Police and\/or other agency.<br>Employees that refuse to accept or offer a bribe, or those who report concerns or<br>wrongdoing can understandably be worried about what might happen as a result. To<br>encourage openness, anyone who reports a genuine concern will be supported<br>under this policy, even if they turn out to be mistaken. There is a commitment to<br>making sure nobody is treated badly because they have refused to take part in<br>bribery or corruption, or because they have reported a concern.<\/p>\n\n\n\n<h3 class=\"wp-block-heading\" id=\"support-guidance\">Further Support & Guidance<\/h3>\n\n\n\n<p class=\"wp-block-paragraph\">If there are any questions about this policy, please speak directly to your line<br>manager or approach the Managing Director, directly.<\/p>\n","protected":false},"excerpt":{"rendered":"<p>WeKnow Media Ltd, the owners of IoT Now, is committed to carrying out its business and relationships professionally and with integrity and ensuring compliance with the requirements of the Bribery \u2026 <a href=\"https:\/\/round-lake.dustinice.workers.dev:443\/https\/iot-now.com\/anti-bribery-policy\/\">Continued<\/a><\/p>\n","protected":false},"author":24373,"featured_media":0,"parent":0,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"_acf_changed":false,"footnotes":""},"class_list":["post-141780","page","type-page","status-publish","hentry"],"acf":[],"_links":{"self":[{"href":"https:\/\/round-lake.dustinice.workers.dev:443\/https\/iot-now.com\/wp-json\/wp\/v2\/pages\/141780","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/round-lake.dustinice.workers.dev:443\/https\/iot-now.com\/wp-json\/wp\/v2\/pages"}],"about":[{"href":"https:\/\/round-lake.dustinice.workers.dev:443\/https\/iot-now.com\/wp-json\/wp\/v2\/types\/page"}],"author":[{"embeddable":true,"href":"https:\/\/round-lake.dustinice.workers.dev:443\/https\/iot-now.com\/wp-json\/wp\/v2\/users\/24373"}],"replies":[{"embeddable":true,"href":"https:\/\/round-lake.dustinice.workers.dev:443\/https\/iot-now.com\/wp-json\/wp\/v2\/comments?post=141780"}],"version-history":[{"count":0,"href":"https:\/\/round-lake.dustinice.workers.dev:443\/https\/iot-now.com\/wp-json\/wp\/v2\/pages\/141780\/revisions"}],"wp:attachment":[{"href":"https:\/\/round-lake.dustinice.workers.dev:443\/https\/iot-now.com\/wp-json\/wp\/v2\/media?parent=141780"}],"curies":[{"name":"wp","href":"https:\/\/round-lake.dustinice.workers.dev:443\/https\/api.w.org\/{rel}","templated":true}]}}