- Private: BRE Way
- Ethics Decision Tree
- Raising Issues of Concern
- Equal Opportunity
- Health, Safety & Wellbeing
- Responsible Sourcing
- Honesty and Integrity
- Bribery and Corruption
- Conflicts of Interest
- Data Protection and Information Security
- External Activities and Communications
- Financial Controls, Records and Reporting
- Gifts and Hospitality
- Media and Stakeholder Communications
- Open and Fair Competition
- Proper Use of Company Property and Resources
- Using Company Computer Systems
- Environmental Impact
Bribery and Corruption
Bribery and corruption are against the BRE Way and against the law, no matter what the local customs in a particular country may be. BRE will not tolerate bribery and corruption in any form.
The risk of bribery and corruption extends beyond the employees of BRE to anyone who works on behalf of or with BRE. Please familiarise yourself and comply with the anti-bribery and corruption rules in this document, and make sure that any third parties you work with, such as agents, partners, and advisors, are aware of them.
BRE endeavours to implement effective measures to prevent, monitor and eliminate bribery, but we depend on individuals playing their part to ensure that the highest standards of business conduct are maintained.
Each and every person working on behalf of and with BRE is expected to remain vigilant in preventing, detecting and reporting bribery. Our reputation depends on it.
What constitutes a bribe?
Under the Bribery Act 2010, a bribe is a financial or other type of advantage that is offered, promised or given to another person with:
- the intention of inducing or rewarding improper performance of a function or activity, or
- knowledge or belief that accepting such a reward would constitute the improper performance of such a function or activity.
It is an offence to offer or receive of a bribe, regardless of where in the world that takes place.
Bribes can include:
- gifts (including by way of services),
- hospitality, and
given as an inducement or reward for something improper.
Q: You are working on a project for a customer abroad. You feel that it would be useful to hire a local subcontractor to help with the groundwork. You were recently contacted by the selected subcontractor who requested £5,000 explaining that they would use the money to ‘grease the wheels’ of the local administration.
what do you do?
A: You are required to decline the payment and you must notify your Line Manager and the Legal team. It is likely that we would reconsider employing this particular subcontractor whose ethics seem to contravene BRE’s. Also bear in mind that the Bribery Act applies regardless of the fact that the proposed event would take place outside the UK.
Dealing with public officials
While our approach to bribery and corruption is generally the same whether the third party in question represents a business or a government, the rule on offering gifts and hospitality to public officials is more clear cut.
Whilst certain business courtesies may be acceptable when dealing with private customers – e.g. paying for a work dinner or sports tickets – they are generally not acceptable when working with public officials. BRE expressly prohibits the direct or indirect offer of gifts and entertainment of any kind to domestic or foreign government officials. Any hospitality offered should be strictly limited to travel and subsistence, and should be reasonable and modest.
Reporting suspected bribery
We expect and encourage you to speak up and report any attempted or suspected bribery or corruption, and incidents of bribes having been offered to you. If you have any questions or concerns, please consult with your Line Manager and/or a representative from BRE’s Legal or Compliance teams.
Dos and Don’ts
- Act in compliance with the BRE Anti-Bribery & Corruption Policy and the applicable anti-bribery and corruption laws.
- Record any type of gift, hospitality and other gratuities regardless of whether it is accepted or not.
- Seek the approval of the Legal team or Compliance team before giving any gifts or entertainment to domestic or foreign public officials.
- Report suspected bribery or corruption to your Line Manager or a representative from the Legal team, Compliance team or Group Board.
- Offer or accept unauthorised payments, gifts or anything else of value, e.g. to win business.
- Deliberately fail to record a gift or hospitality for fear of reprimand – it is their concealment that can lead to a reprimand!