Anti-bribery Policy

Effective Date: 11th September 2024

1. Purpose

Shoothill is committed to conducting business in an ethical, honest, and transparent manner. We have a zero-tolerance approach to bribery and corruption, and we are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships, wherever we operate. This policy outlines our position on preventing and prohibiting bribery, in compliance with the UK Bribery Act 2010.

2. Scope

This policy applies to all employees, officers, consultants, contractors, interns, volunteers, and any other persons associated with Shoothill or any of its subsidiaries (“Employees”). It also applies to third parties including agents, intermediaries, and other business partners who act on behalf of Shoothill.

3. Definition of Bribery

Bribery refers to the offering, promising, giving, accepting, or soliciting of an advantage as an inducement for action which is illegal, unethical, or a breach of trust. Bribery can take many forms, including:

  • Offering, promising, or giving a financial or other advantage to another person to induce or reward them for performing their duties improperly.
  • Requesting, agreeing to receive, or accepting a financial or other advantage to perform duties improperly.

4. Prohibited Conduct

Shoothill strictly prohibits:

  • Offering, giving, or receiving bribes or inducements to or from any person or organization.
  • Making facilitation payments to expedite routine governmental actions.
  • Engaging in any form of corruption, extortion, or influence peddling.
  • Making political or charitable donations to influence business outcomes.

5. Gifts and Hospitality

While gifts and hospitality can be a legitimate part of building business relationships, they should never influence business decision-making or create a sense of obligation. Employees should ensure that any gifts or hospitality provided or received are:

  • Reasonable, proportionate, and given in good faith.
  • Not intended to improperly influence a business decision or outcome.
  • Fully disclosed and recorded in accordance with Shoothill’s procedures.

If you are unsure whether a gift or hospitality is appropriate, seek guidance from your line manager or the Compliance Officer.

6. Employee Responsibilities

All Employees must:

  • Comply with this policy and all relevant laws related to anti-bribery and corruption.
  • Avoid any activity that might lead to, or suggest, a breach of this policy.
  • Report any concerns or suspicions of bribery or corruption immediately to the Compliance Officer or through the Whistleblowing Procedure.
  • Complete all anti-bribery and corruption training provided by Shoothill.

7. Third-Party Relationships

Shoothill expects all third parties acting on its behalf to comply with this policy. We will perform due diligence on all business partners, agents, suppliers, and contractors to ensure they are aware of and comply with anti-bribery laws. Any third party found to be in breach of this policy may have their contract terminated.

8. Record Keeping

Shoothill will maintain accurate financial records and have appropriate internal controls in place to evidence the business reason for making payments to third parties. All expenses claims relating to hospitality, gifts, or payments to third parties must be submitted in accordance with our expenses policy and be accurately recorded.

9. Monitoring and Review

Shoothill will regularly review this policy and its procedures to ensure they remain effective in preventing bribery and corruption. Employees will be notified of any changes.

10. Consequences of Breach

Any Employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Shoothill may also terminate its relationship with other individuals and organizations working on its behalf if they are found to be in breach of this policy.

11. Reporting Concerns

Employees are encouraged to report any concerns regarding bribery or corruption at the earliest opportunity. Concerns should be reported to the Compliance Officer or through our Whistleblowing Procedure. Reports will be treated confidentially and without fear of reprisal.

12. Contact Information

For questions about this policy or to report any concerns, please contact:

Compliance Officer

Simon Jeavons
Group Managing Direcotr
Shoothill Ltd