OUR DEFINITION:

 

Corruption generates decisions for unlawful reasons, prevents progress and innovation, distorts competition, and harms companies. It is therefore prohibited under law and can hence lead to fines for the company and criminal prosecution for the director concerned. We are committed to fighting corruption in any form from across the world. We, therefore, support national & international efforts to combat corruption. This applies, in particular, to granting so-called acceleration payments (”Facilitation Payments” - payments of small amounts directly to the responsible officials). 

 

OUR POLICY:

 

NSG is committed to maintaining its established reputation for lawful and ethical behavior and for financial integrity in all aspects of its business. We have zero-tolerance for corruption, fraud, and criminality (including financial crime), and the giving or receiving of bribes for any purpose.

 

We aim to minimize our business's exposure to bribery and corruption by:

 

• maintaining a culture where bribery or corruption is unacceptable;

 

• encouraging third-parties to report any suspicion of corruption, bribery, or misconduct;

 

• widely communicating the company’s Anti-Bribery & Corruption policy, providing bribery and other appropriate training to all third parties;

 

• understanding and following anti-financial crime legislation;

 

• maintaining a clear Hospitality Procedure relating to the acceptance and offering of gifts & benefits;

 

• supporting any person who reports bribery or corruption in good faith, and protecting them from victimization;

 

• making our political engagement policy and procedures available to all interested parties

 

Anti Bribery & Corruption Policy 

DEFINITION

 

Corruption involves dishonest or illegal behavior, deception, and/or concealment (whether for personal gain or perceived operational benefit).

 

DIFFERENCE BETWEEN CORRUPTION & BRIBERY

 

Corruption can typically include activities such as theft, misreporting, conspiracy, embezzlement, or financial crimes

such as money laundering, tax evasion, or terrorist financing.

 

Bribery is where a financial (or other) advantage is given or received to improperly induce performance of functions or activities, or to reward a person for already having done so. Examples of bribery include:

 

• the giving or receiving of cash, gifts, credits, discounts,

hospitality, travel, accommodation, services, or the awarding

of contracts to procure a personal or business advantage;

 

• inducing those with a public function to perform it improperly (e.g. to make a favorable decision);

 

• enticement to speed up routine actions or processes.

PENALTIES

 

Individuals, employees, managers, directors, and companies can all be held accountable for bribing other individuals or organizations under the UK Bribery Act 2010 (UKBA), with serious or complex fraud and corruption overseen by the Serious Fraud Office (SFO) in England, Wales and Northern Ireland; in Scotland, by Police Scotland and the Crown Office and Procurator Fiscal Service.

 

Penalties for bribery offenses include imprisonment for up to 10 years

and unlimited fines. Directors may also be disqualified from acting as a director, and companies banned from entering into public sector contracts.

 

REPORTING

 

Reporting suspected bribery or corruption confidentially to its nominated contact - encourages our independent external reporting officer to undertake an investigation and where warranted to take action, often in some instances legally.

 

Email: Safeguarding@nsg.org.uk

For financial crime matters, email: crime@nsg.org.uk