1: Introduction

1.1 Policy Overview
Redcone Recruitment Limited is committed to conducting all business operations with the highest levels of integrity, transparency, and ethical conduct. This Anti-Bribery and Corruption Policy outlines the company’s zero-tolerance approach to bribery and corruption and its commitment to complying with all relevant anti-corruption legislation, including the UK Bribery Act 2010. The policy applies to all employees, contractors, suppliers, and third parties who engage with Redcone Recruitment Limited. The company recognises the significant risks posed by bribery and corruption and is dedicated to preventing any unethical practices that could damage its reputation or relationships with clients, partners, and regulators.

1.2 Purpose of the Policy
The purpose of this policy is to:

• Ensure compliance with the UK Bribery Act 2010 and other relevant laws that prohibit bribery and corruption.
• Provide clear guidance to employees and third parties on the standards of behaviour expected in relation to bribery and corruption.
• Establish procedures for identifying and preventing bribery and corruption within Redcone Recruitment Limited’s operations.
• Protect the company from the risks associated with bribery and corruption, including legal penalties, reputational damage, and financial losses.
• Promote a culture of integrity, transparency, and accountability across all levels of the organisation.

1.3 Legal Framework
This policy complies with the UK Bribery Act 2010, which makes it an offence to:

• Offer, promise, or give a bribe.
• Request, agree to receive, or accept a bribe.
• Bribe a foreign public official to obtain or retain business.
• Fail to prevent bribery by a person associated with an organisation.

The company also follows international standards, such as ISO 37001 (Anti-Bribery Management Systems), to ensure best practices in its anti-bribery and corruption efforts.

2: Scope

2.1 Applicability
This policy applies to all employees of Redcone Recruitment Limited, including full-time, part-time, temporary, and contracted staff. It also extends to third parties acting on behalf of the company, including consultants, agents, suppliers, vendors, contractors, and joint venture partners. The policy applies to all business activities and transactions conducted by Redcone Recruitment Limited, both in the UK and abroad.

2.2 Definition of Bribery and Corruption

• Bribery: Bribery refers to offering, giving, receiving, or soliciting something of value, whether monetary or otherwise, with the intention of influencing the actions of an individual or organisation in a position of power or authority to secure an unfair advantage.
• Corruption: Corruption refers to the abuse of entrusted power for private gain, which may involve bribery, fraud, embezzlement, or other forms of unethical behaviour.

Examples of bribery and corruption include:

• Offering money to a government official to speed up the approval of permits.
• Accepting gifts or hospitality in return for awarding a contract.
• Making payments to secure a favourable business deal or to prevent legal penalties.

3: Policy Details

3.1 Prohibited Conduct
Redcone Recruitment Limited prohibits any form of bribery or corruption, including but not limited to:

• Offering Bribes: No employee or third party acting on behalf of the company may offer, promise, or give a bribe to any individual, organisation, or public official with the intent to influence them or gain an improper business advantage.
• Accepting Bribes: No employee or third party acting on behalf of the company may solicit, agree to receive, or accept a bribe in exchange for giving or promising any favourable treatment or advantage.
• Facilitation Payments: Redcone Recruitment Limited does not allow the use of facilitation payments, which are small, unofficial payments made to secure or expedite routine actions by public officials, such as issuing permits or processing paperwork.
• Kickbacks: No employee or third party acting on behalf of the company may give or accept kickbacks, which are illicit payments made as a return for securing a contract or other benefits.

3.2 Gifts and Hospitality
Redcone Recruitment Limited recognises that gifts and hospitality, when offered appropriately, can foster good business relationships. However, they must never be used to influence business decisions improperly. The following rules apply:

• Permitted Gifts and Hospitality: Reasonable, occasional, and proportionate gifts and hospitality that are offered for legitimate business purposes, such as building relationships or expressing appreciation, may be accepted or given. Such offerings should not exceed £50 in value without prior written approval from a senior manager.
• Prohibited Gifts and Hospitality: Any gifts or hospitality that are excessive, given in cash or equivalents, or intended to influence a business decision or secure an improper advantage are strictly prohibited.
  Employees must not accept gifts or hospitality from individuals or organisations during a tendering or contracting process.

3.3 Political and Charitable Donations

• Political Donations: Redcone Recruitment Limited does not make political donations, whether in cash or in kind, to any political party, candidate, or campaign, either in the UK or internationally.
• Charitable Donations: Any charitable donations made by the company must be transparent, legal, and for legitimate charitable purposes. Employees may not use charitable donations as a means to disguise or facilitate bribery or other improper conduct.

3.4 Third-Party Relationships
Redcone Recruitment Limited expects all third parties, including agents, consultants, contractors, and suppliers, to comply with this Anti-Bribery and Corruption Policy. The company will not engage in business with any third party known or suspected to be engaging in bribery or corruption. Third parties are required to adhere to the following:

• Due Diligence: Prior to engaging with third parties, Redcone Recruitment Limited will conduct due diligence to assess the risk of bribery or corruption. This may include reviewing the third party’s business practices, reputation, and history of compliance.
• Contractual Obligations: All contracts with third parties will include provisions requiring adherence to anti-bribery and corruption laws and this policy.
• Monitoring and Auditing: Redcone Recruitment Limited reserves the right to monitor and audit third-party relationships to ensure compliance with this policy.

4: Risk Assessment and Due Diligence

4.1 Risk Assessment
Redcone Recruitment Limited recognises that certain business activities or regions may present a higher risk of bribery and corruption. The company will conduct regular risk assessments to:

• Identify areas of the business most vulnerable to bribery and corruption.
• Evaluate the effectiveness of existing controls and procedures.
• Implement measures to mitigate any identified risks.

4.2 Due Diligence Procedures
Redcone Recruitment Limited will carry out due diligence on new and existing business partners, agents, contractors, and other third parties. The due diligence process will include:

• Verifying the background, reputation, and track record of the third party.
• Ensuring that the third party complies with relevant anti-bribery laws and has adequate policies and procedures in place.
• Ongoing monitoring of third-party relationships to ensure continued compliance.

5: Reporting and Investigation

5.1 Reporting Bribery and Corruption
Redcone Recruitment Limited encourages all employees and third parties to report any concerns or suspicions of bribery or corruption. Reports can be made confidentially through the company’s whistleblowing procedure or directly to a line manager or the compliance officer. The company guarantees that no employee or third party will face retaliation for reporting a genuine concern in good faith.

5.2 Investigation Procedures
All reports of bribery or corruption will be investigated promptly, thoroughly, and confidentially. Redcone Recruitment Limited will take appropriate action if evidence of bribery or corruption is found, which may include:

• Disciplinary action against employees involved, up to and including termination of employment.
• Termination of contracts with third parties found to be in breach of this policy.
• Reporting the matter to the relevant authorities, if necessary, and cooperating fully with any external investigation.

6: Training and Communication

6.1 Employee Training
Redcone Recruitment Limited is committed to ensuring that all employees understand the risks of bribery and corruption and are aware of their responsibilities under this policy. The company will provide regular training on anti-bribery and corruption for all employees, particularly those in roles that are deemed high-risk, such as procurement, sales, or working in foreign jurisdictions.

6.2 Communication of the Policy
This Anti-Bribery and Corruption Policy will be communicated to all employees, contractors, and third-party partners. The policy will also be available on the company’s intranet and shared with new employees as part of their induction process. External stakeholders, including suppliers and clients, will also be made aware of the company’s stance on bribery and corruption through contracts and formal communications.

7: Responsibilities

7.1 Employee Responsibilities
All employees are required to:

• Familiarise themselves with this policy and adhere to its provisions at all times.
• Report any concerns about possible bribery or corruption to their line manager or the compliance officer.
• Refuse any offers of bribes or kickbacks and avoid engaging in any form of unethical behaviour.

7.2 Managerial Responsibilities
Managers are responsible for:

• Ensuring that their teams understand and comply with the Anti-Bribery and Corruption Policy.
• Identifying areas of high risk and implementing measures to mitigate those risks.
• Acting as role models in promoting ethical behaviour and integrity in business dealings.

7.3 Compliance Officer Responsibilities
The Compliance Officer is responsible for:

• Overseeing the implementation of the Anti-Bribery and Corruption Policy.
• Conducting regular risk assessments and reviewing the effectiveness of anti-bribery controls.
• Investigating any reported cases of bribery or corruption and ensuring appropriate action is taken.

8: Consequences of Policy Violation

8.1 Employee Disciplinary Actions
Any employee found to be involved in bribery or corruption will face serious disciplinary action, which may include:

• Formal warnings.
• Demotion or suspension.
• Termination of employment.

8.2 Third-Party Termination
Any third party found to be in breach of this policy will have their contract with Redcone Recruitment Limited terminated. The company may also seek legal recourse, including compensation for any damages caused by the violation.

8.3 Legal Consequences
Bribery and corruption are criminal offences under the UK Bribery Act 2010 and other international laws. Individuals found guilty of these offences may face imprisonment, significant fines, and a permanent criminal record. Redcone Recruitment Limited reserves the right to report instances of bribery or corruption to the relevant authorities, where appropriate.

9: Monitoring and Review

9.1 Policy Monitoring
Redcone Recruitment Limited will monitor the implementation and effectiveness of this policy through regular internal audits, risk assessments, and feedback from employees and third parties. The company will review any incidents of bribery or corruption to assess the effectiveness of current controls and make improvements where necessary.

9.2 Policy Review
This policy will be reviewed annually or in response to changes in legislation or business practices. Any updates to the policy will be communicated to all employees and third-party stakeholders.

10: Conclusion

Redcone Recruitment Limited is fully committed to operating with integrity, transparency, and accountability. Adherence to this Anti-Bribery and Corruption Policy is mandatory for all employees and third parties associated with the company. By complying with this policy, Redcone Recruitment Limited aims to maintain the highest standards of ethical conduct and protect the company from the risks associated with bribery and corruption.