Anti-bribery and corruption policy

Our position

AGL Construction Services Ltd does not offer, pay, ask for or accept bribes, in any form. We win work on price, quality and our record, and on nothing else.

This policy applies to our directors and employees, and to everyone who acts for us, including the specialist trades and suppliers we work with.

What the law says

The Bribery Act 2010 makes it a crime to offer or give a bribe, to ask for or accept one, and to bribe a foreign public official. A bribe is anything of value, such as money, gifts, hospitality or favours, given to make someone act improperly.

A company also commits an offence if someone acting for it pays a bribe, unless it has adequate procedures to prevent bribery. This policy is part of the procedures we keep for that purpose.

Facilitation payments, small unofficial payments to speed up a routine process, are bribes too. We do not make them.

Gifts and hospitality

Modest gifts and hospitality can be part of normal business. They must never be offered or accepted to influence a decision.

• Token items, such as a diary or a small seasonal gift, are fine.
• Anything more than a token must be declared to a director, who will record it and decide whether it is acceptable.
• Never give or accept cash or vouchers.
• Never offer anything to someone who is deciding on a tender or contract we are involved in.
• Council and housing association staff have their own strict rules on gifts, and we respect them.

Conflicts of interest

A conflict of interest arises when a personal interest could affect, or seem to affect, a decision you make for AGL. Examples include a relative who works for a supplier or a client, or a stake in another business we deal with. Declare any conflict to a director as soon as you are aware of it. Declaring a conflict is not wrongdoing; hiding one is.

Tendering and payments

• We compete fairly and follow each client's procurement rules.
• We never agree prices or bids with competitors, or seek confidential information to gain an advantage.
• We choose specialists and suppliers on quality, price and reliability, and expect them to act honestly when they work for us.
• Payments are properly approved and recorded, so our accounts show what was paid, to whom and why.

Reporting a concern

If you are offered or asked for a bribe, refuse and tell a director straight away. Do the same if you suspect bribery by anyone connected with our work. You can also raise a concern in confidence under our whistleblowing policy.

No one will suffer for refusing to pay or accept a bribe, or for reporting a concern in good faith, even if we lose business as a result.

Breaches

We treat any breach of this policy seriously. For employees it is a disciplinary matter, which may lead to dismissal. For specialists, suppliers and anyone else acting for us, it may mean the end of our work with them. Where the law may have been broken, we may report it to the police or other authorities.

Responsibilities and review

The directors of AGL Construction Services Ltd own this policy, lead by example and make sure it is shared with everyone who acts for us. They review it every year, and sooner if the law or our work changes.