At SCG we are committed to doing the right things and in the right way. Our Code of Ethics outlines the standards and behaviours that we hold, to ensure the highest standards of honesty and integrity. We operate a ZERO tolerance approach to the making or receiving of bribes or corrupt payments, in any form. This type of conduct is absolutely prohibited whether committed by employees or anyone acting on behalf of the company.
What is a bribe?
A bribe may include any payment, benefit or gift offered or given with the purpose of influencing a decision or outcome. The bribe may not always be of large value. It could be a lunch or an invitation to a sporting event. We recognise that market practices vary. However, we are fully committed to complying with our obligations under the Bribery Act 2010 (the “Act”) and ensuring that no bribes or corrupt payments are made, offered, sought or obtained by anyone acting on our behalf, to anyone, anywhere in the world.
Who must comply?
The Anti-Bribery policy is mandatory for all SCG Partners, Franchisees, their agents and employees, intermediaries, consultants, sub-contractors, etc, working on behalf of SCG anywhere in the world. The prevention, detection and reporting of any bribery in any form is the responsibility of ALL across SCG and all individuals and entities over which SCG has control. Appropriate confidential channels are in place to report any suspicion of bribery, described in this policy. You must read and abide by the terms of this policy. You may also be required to provide written confirmation that you will comply with this policy, by signing the Code of Ethics.
What happens if you don’t comply?
Any act of bribery is unacceptable. We will consider strict disciplinary action against anyone who fails to comply with the anti-bribery policy up to and including dismissal. Failure to comply with this policy may leave you open to criminal prosecution under this Act. An offence under the Act can result in a fine and/or up to a maximum of 10 years imprisonment.
What you cannot do?
Make unofficial payments to officials in order to obtain any permission, permit or stamp particularly in connection with any transaction.
Appoint any third party to act on behalf of SCG who you know or have good reason to believe to have engaged in any corrupt or unlawful conduct including any offences under the Act.
Pay any third party for the purposes of being a “fixer” to open doors and make connections for us overseas.
Facilitation payments (facilitating, speed back-hander, or grease payments) are payments, usually small cash payments made to low level officials, as a bribe to secure or expedite the performance of a routine or necessary action or level of service. No one must offer, pay, solicit, or accept bribes in any form, including facilitation payments.
SCG does not make any contributions or donations to political organisations or independent candidates, nor does it incur any political expenditure. We respect the right of individuals to make personal contributions, provided they are not made in any way to obtain advantage in a business transaction.
Charitable donations are part of SCG’s giving and supporting the community initiative. Donations are given to company identified charities in accordance with company policy on donations to charitable organisations.
What should you do?
We believe it is essential to create an environment in which you feel safe to raise any matters of genuine concern internally without fear of disciplinary action being taken against you, that you will be taken seriously and that the matters will be investigated appropriately and as far as practicable be kept confidential. Complaints may be made in writing directly to:
The Director, Ethics
Strategy Consulting Group Limited
121 Watford Road, Croxley Green, Rickmansworth, WD3 3DX, Hertfordshire
In your communication please state the contact person, address for communication, email, telephone, mobile number and reason for the concern.
Issue handling process
All issues related to bribery are entered into an Anti-Bribery Risk Register on receipt and a written response is sent within 14 working days.
The Director, Ethics assesses the complaint to determine whether it is directly relevant to the scope of activities and contravenes any provisions of the Act.
If the complaint is not within the jurisdiction of the scope, the complainant is advised and no further action is required by SCG to be taken
If the complaint is within the jurisdiction of the scope, the complaint will be referred to a Partner, for an internal review. The complainant will be advised of the outcome of the process within 3 weeks where possible
The decision of the Partner will be final. The result of the review will be communicated in writing to the complainant and The Director, Ethics
If upheld The Director, Ethics will take appropriate action to redress the complaint
The Director, Ethics will update the Anti-Bribery Risk Register with the outcome of the review.