Anti-Bribery & Corruption Policy

Norwich Car Centre Ltd / Norwich Car Centre is committed to high ethical standards. Our policies on anti-money laundering, sanctions, and anti-bribery and corruption aim to ensure that risks identified by the company are appropriately mitigated.

The company ensure that money laundering risks identified by FCA are appropriately mitigated. This is achieved by establishing Board-approved, minimum governing policies, principles, and standards and implementing appropriate controls, to protect the Company, its employees; shareholders and customers from money laundering.

What does this policy cover?

This anti-bribery policy exists to set out the responsibilities of and those who work for us in regard to observing and upholding our zero-tolerance position on bribery and corruption. It also exists to act as a source of information and guidance for those working for. It helps them recognise and deal with bribery and corruption issues, as well as understands their responsibilities.

Policy Statement

Norwich Car Centre Ltd / Norwich Car Centre is committed to conducting business in an ethical and honest manner and is committed to implementing and enforcing systems that ensure bribery is prevented.

Norwich Car Centre Ltd / Norwich Car Centre zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships.

Norwich Car Centre Ltd / Norwich Car Centre will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, regarding our conduct both at home and abroad.

Norwich Car Centre Ltd / Norwich Car Centre that bribery and corruption are punishable by up to ten years of imprisonment and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business, and take our legal responsibilities seriously.

What is covered by the Policy

This anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK). The policy also applies to Officers, Trustees, Board, and/or Committee members at any level.

In the context of this policy, third-party refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies - this includes their advisors, representatives and officials, politicians, and public parties.

Any arrangements our company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to anti-bribery and corruption.

Definition of Bribery

Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision.

A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.

Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.

Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the company's compliance manager.

What is and is NOT acceptable

This section of the policy refers to 4 areas:

  • Gifts and hospitality
  • Facilitation payments
  • Political contributions
  • Charitable contributions

Gifts and hospitality

Norwich Car Centre Ltd / Norwich Car Centre normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements:

  • a. It is not made with the intention of influencing the party to whom it is being given...
  • b. It is not made with the suggestion that a return favour is expected.
  • c. It is in compliance with local law.
  • d. It is given in the name of the company, not in an individual's name.
  • e. It does not include cash or a cash equivalent.
  • f. It is appropriate for the circumstances.
  • g. It is of an appropriate type and value...
  • h. It is given/received openly, not secretly.
  • i. It is not selectively given to influence an individual.
  • j. It is not above an excessive value (usually £100).
  • k. It is not offered to or accepted from a government official without prior approval.

Where it is inappropriate to decline a gift, the gift may be accepted so long as it is declared to the compliance manager.

As good practice, gifts should always be disclosed to the compliance manager. Gifts from suppliers should always be disclosed.

Facilitation Payments and Kickbacks

Norwich Car Centre Ltd / Norwich Car Centre does not accept and will not make any form of facilitation payments of any nature.

Norwich Car Centre Ltd / Norwich Car Centre does not allow kickbacks to be made or accepted.

If avoiding a facilitation payment or kickback puts personal safety at risk, employees must:

  • a) Keep the amount to the minimum
  • b) Ask for a receipt
  • c) Create a record
  • d) Report the incident

Political Contributions

Norwich Car Centre Ltd / Norwich Car Centre will not make donations of any kind to political parties or candidates.

Charitable Contributions

Norwich Car Centre Ltd / Norwich Car Centre encourages charitable giving but requires transparency and compliance with law.

Employees Responsibility

Employees must read, understand, and comply with this policy. They must report bribery concerns to the compliance manager.

Breaching this policy may result in disciplinary action or dismissal.

What happens if I need to raise a concern?

A: How to raise a concern

Concerns should be raised early with a line manager, compliance manager, or director.

B: What to do if you are a victim

Employees must report bribe offers or suspected bribery immediately.

C: Protection

Norwich Car Centre Ltd / Norwich Car Centre supports those who refuse to take part in bribery or report concerns.

Training and communication

Training will be provided at induction and regularly thereafter. Suppliers and partners will be made aware of our zero-tolerance stance.

Record Keeping

Norwich Car Centre Ltd / Norwich Car Centre will maintain accurate financial and gift records.

Monitoring & Reviewing

The compliance manager will regularly review this policy and procedures to ensure effectiveness.