1. PURPOSE
J A Stott (Carpentry) Ltd expect the highest ethical standards from all J A Stott (Carpentry) Ltd employees and other personnel in carrying out J A Stott (Carpentry) Ltd’s business. We must all conduct our business in an honest and ethical manner, with integrity, and in compliance with the spirit and the letter of the law. It is usually clear how we should confront any attempts at theft, fraud, bribery or corruption that we meet in the ordinary course of business.
The purpose of this Policy is to protect employees and minimise loss by providing clear guidelines on Fraud and Theft, or the misuse of Customer property and Company cash, which includes unauthorised borrowing, deception, bribery, forgery, corruption, false accounting and conspiracy.
This policy will be used in conjunction with the Company’s Whistleblowing Policy which is available to all employees.
2. SCOPE
The policy applies to all J A Stott (Carpentry) Ltd employees including contract or agency staff and its customers.
3. POLICY STATEMENT
The policy seeks to minimise the financial and reputational damage that can be caused to J A Stott (Carpentry) Ltd through theft, fraud, bribery or corruption. In addition this policy aims to give clarity to all employees on their responsibilities in declaring any conflicts of interest to J A Stott (Carpentry) Ltd.
J A Stott (Carpentry) Ltd regards fraud and theft by its employees as an extremely serious offence. Fraud and theft not only lead to financial loss to the business but may also damage its reputation as a customer service provider and as an employer.
The Organisation requires all staff at all times to act honestly and with integrity, and to safeguard the resources for which they are responsible.
Customer or Company property, cash or products, may not be removed from the Company premises without prior written approval from Commercial Director/Line Manager or above.
It is the Company policy to seek prosecution of employees who it reasonably believes are in unauthorised possession of Company, or other people’s property or cash, and for any other criminal offences relating to the Company’s property, business and its activities. Failure to adhere to this policy could lead to formal disciplinary action which may result in dismissal.
3.1 Policy Overview
Fraud
Fraud of any kind will not be tolerated. J A Stott (Carpentry) Ltd is committed to the prevention, detection and proper investigation of fraud, with an overriding aim to prevent the occurrence of fraud in the first instance.
All employees have a responsibility to be alert to the signs of fraud, to prevent fraud where possible and to report suspected fraud.
J A Stott (Carpentry) Ltd will respond to all incidents, seek to recover losses, take action against those who perpetrate fraud and report incidents to the authorities, as appropriate.
Bribery
In accordance with the Bribery Act (2010), J A Stott (Carpentry) Ltd does not permit any person involved in the business to engage in bribery. As detailed in the Act, J A Stott (Carpentry) Ltd personnel and agents must not:
• directly or indirectly authorise, offer, promise, pay or give any bribe, kickback or facilitating payment, or any other financial or commercial advantage, even where local law against such payments are not enforced;
• directly or indirectly solicit, request or accept any bribe or kickback, or other financial or commercial advantage (whether for the Company’s benefit, their own benefit or that of their family, friends, associates or acquaintances).
Any demands received by J A Stott (Carpentry) Ltd for a bribe, kickback or facilitating payment must be rejected and reported to the Commercial Director in writing.
Gifts & Hospitality
No J A Stott (Carpentry) Ltd employee or family member may accept, solicit or give any improper gift or hospitality, without written authorisation from a J A Stott (Carpentry) Ltd Director.
For the purpose of this policy hospitality, entertainment and gifts can include travel and accommodation, social or sporting events, or other benefits received or given in the context of providing or receiving gifts and entertainment.
They can also include discounts or free products. This applies to both giving and receiving gifts or hospitality and applies internally to all employees, employees’ family members and external to any third-party stakeholder including suppliers, customers and sub-contractors.
Where such gifts are offered, regardless of acceptance, these must be reported to the Commercial Director/Company HR representative. A record will be maintained by the Company HR representative and audited annually by the Commercial Director or nominated Company Auditors.
Conflict of Interest
J A Stott (Carpentry) Ltd understand that some employees may have a conflict of interest that the Company should be aware of. These can include:
– Additional employment that can contradict the Working Time Regulations
– A close family member working for a direct competitor
– An interest in a business that J A Stott (Carpentry) Ltd deems to be a direct competitor
Where such a conflict exists, the employee should notify the Company HR representative in writing and ensure they receive confirmation of their notification.
In some circumstances, where the Company deems the conflict to be serious, the Company may conduct an investigation which could result in the Company taking any necessary protective measures including an alternate role or termination of employment.
4. FRAUD AND THEFT POLICY REQURIMENTS
The Company will expect all employees to:
• Make every effort to ensure the security of the building, all cash and stock handling and staff discount schemes are strictly adhered to.
• Ensure that they are aware and compliant with the requirements stated in this Policy.
• Ensure security keys, access fobs etc. are adequately secured at all times.
• Identify and investigate any discrepancies in cash, stock, etc.
• If authorised to do so, carry out a search in accordance with the procedures outlined in the Right to Search Policy.
• Report any potential loss to the relevant Line Management.
5. GIFTS AND HOSPITALITY POLICY REQUIREMENTS
The Company will expect all employees or family members to:
• Refuse to accept, solicit or give (directly or indirectly) any improper gift or hospitality.
• Obtain their Line Manager’s consent before giving or accepting any gift.
• Obtain the Company HR representative’s or Commercial Director’s consent before giving or accepting any hospitality or entertainment with a value above £50.
6. PROVISION UNDER THE POLICY
6.1 Right to Search
November 2020 Uncontrolled when copied Page 3 of 3 IMS Reference 1.1.3
The right to search is a condition of employment and an employee’s refusal to submit to a search could result in disciplinary action being taken in line with the Company Disciplinary Procedure.
6.2. Authorised Possession of Company Property
Employees wishing to use Company property outside their normal place of work, for business or other purposes, must ensure that they receive written authorisation from their Line Manager. Responsibility for these items remains with the employee until they are returned.
6.3. Unauthorised Possession of Company Property
Where fraud, theft or borrowing by an employee is reasonably suspected through search, or highlighted by other methods, the Company reserves the right to suspend an employee on full pay pending a full and fair investigation. Action to dismiss for unauthorised possession of Company property will only be taken when all of the facts have been established in accordance with the Company Disciplinary Procedure.
Action taken is separate from, and usually in advance of, any action taken under Police and Criminal Law. Any potential prosecution is to be discussed with the Company HR representative or the Commercial Director in the first instance.
Where outstanding loss is not recovered in full, the Company will consider taking legal action to recover property and costs.
The Directors of J A Stott (Carpentry) Ltd will monitor and review the operation of this policy on an annual basis to endeavour that it remains relevant and appropriate to the company and will make available the statement, organisation and arrangements sections of the policy in prominent positions in the offices and workplace for inspection by all employees and other interested parties.
Signed:
Name: John Kane
Position: Construction Director
Date: 20/11/20
