Antibribery & corruption


This anti-bribery policy exists to set out the responsibilities of Nicholson STS Ltd 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 Nicholson STS Ltd and to help them to recognise and deal with bribery and corruption issues, as well as understand their responsibilities.

Policy statement

Nicholson STS Ltd is committed to conducting business in an ethical and honest manner to implementing and enforcing systems that ensure bribery is prevented. Nicholson STS Ltd has zero-tolerance for bribery and corrupt activities. Integrity is one of the core values promoted by the company and we are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.

Nicholson STS Ltd 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, in regard to our conduct both at home and abroad.

Who is affected by this 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 the company (including third parties), no matter where they are located (within or outside of the UK). The policy also applies to Officers, Trustees, Board members, and/or Committee members at any level.

In the context of this policy, third-party refers to any individual or organisation our company 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 Nicholson STS Ltd 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 offering a bribe. If an individual is offered 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 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 a Director.

This policy is not meant to prohibit normal and appropriate hospitality or the giving of a gift on a festival or at another special time, providing they are customary in a particular market, are proportionate and are properly recorded.

Decisions as to what is acceptable may not always be easy. If you are in any doubt as to whether a potential act constitutes bribery, the matter should be referred to a Director before proceeding.

Gifts and hospitality

Normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) are acceptable so long as the giving or receiving of gifts meets the following requirements:

  • It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage.
  • It is not made with the suggestion that a return favour is expected.
  • It is compliant with local law.
  • It is given in the name of the company, not in an individual’s name.
  • It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).
  • It is appropriate for the circumstances (e.g. giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).
  • It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.
  • It is given or received openly, not secretly.
  • It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.
  • It is not excessive in value, as determined by the company’s normal gifting protocol (usually under £100 in value).
  • It is not offered to, or accepted from, a government official or representative or politician or political party.
  • As good practice, gifts given and received should always be disclosed to a Director. Gifts from suppliers should always be disclosed.
  • The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of a Director should be sought.
Facilitation Payments and Kickbacks

Nicholson STS Ltd does not accept and will not make any form of facilitation payments of any nature and does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage.

Political Contributions

Nicholson STS Ltd will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates.

Charitable Contributions

Nicholson STS Ltd accepts (and indeed encourages) the act of donating to charities – whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes.

Employees must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery and to ensure that all charitable donations made are legal and ethical under local
laws and practices, and that donations are not offered/made without the approval of a Director.

Employee Responsibilities

As an employee of Nicholson STS Ltd, you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other anti-bribery and corruption information you are given.

You are also encouraged to be vigilant and report any suspicion of bribery to a Director. This includes any activities that could lead to, or imply, a breach of this anti-bribery policy.

If you have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, you must report it in confidence to a Director.

If any employee breaches this policy, they could face disciplinary action and could face dismissal for gross misconduct.

How to raise a concern

If you suspect that there is an instance of bribery or corrupt activities you are encouraged to raise your concerns as soon as possible. If you are uncertain about whether a certain action or behaviour can be
considered bribery or corruption, you should speak to a Director.

You must inform a Director as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity.

If you refuse to accept or offer a bribe, or you report a concern relating to potential act(s) of bribery or corruption, Nicholson STS Ltd understands that you may feel worried about potential repercussions and will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken.

Training and communication

Nicholson STS Ltd will provide training on this policy for all employees and it is reinforced in the Employee Handbook received by all employees. Employees will also receive relevant training on how to adhere to this policy and will be asked to formally accept that they will comply with this policy from time to time.

Nicholson STS Ltd’s anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third-parties at the outset of business relations, and as appropriate thereafter.

Where deemed relevant and appropriate, anti-bribery and corruption training will be provided to employees where we feel their knowledge of how to comply with the Bribery Act is likely to be required in the course of their work activities.

Record keeping

Nicholson STS Ltd will keep detailed and accurate financial records, and will have appropriate internal controls in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given, and understand that gifts and acts of hospitality are subject to managerial review.

Monitoring and review

The Compliance Manager is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness.

Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure that they are effective in practice. Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the Compliance Manager.

This statement was approved by the Board of Directors

Paul Boyt, Managing Director, Nicholson STS Ltd