Anti Bribery POLICY
JUNE 2024
VERSION HISTORY
Date Version Reason For Change
12/06/24 1.0 Initial Release
The Good Marketer is committed to conducting business ethically and with integrity. This Anti-Bribery Policy outlines our zero-tolerance stance towards bribery and corruption.
The purpose of this policy is to:
- Ensure compliance with the Bribery Act 2010.
- Prevent the offering, giving, receiving, or soliciting of bribes in any form.
- Protect the reputation of The Good Marketer.
This policy applies to all employees, directors, agents, contractors, consultants and any other persons associated with The Good Marketer, collectively referred to as “employees” in this policy.
Definition of Bribery
Bribery refers to offering, giving, receiving, or soliciting something of value as a means to influence the actions of an individual holding a public or legal duty.
Prohibited Conduct
Employees must not offer, give, or receive bribes or improper payments.
Payments made in return for a business favour or advantage are prohibited.
The agency must not offer, give or accept any gift or hospitality with explicit or implicit expectations of a business favour or advantage.
Guidelines for Sending Gestures of Goodwill and Receiving Client Gifts
The Good Marketer values its relationships with clients and recognises that goodwill gestures can strengthen these partnerships. We also recognise that employees may occasionally be offered gifts or hospitality by clients or other professionals with whom they work closely. However, it is essential to ensure that such gestures are made ethically, transparently, and in compliance with legal and regulatory requirements, including the Bribery Act 2010 on both the Agency and Client Side.
Approval
Any gesture of goodwill intended for a client or gift/hospitality offered by a client or professional contact must not exceed the value threshold of £50 and must be reported to and approved by a senior manager prior to being sent or accepted to ensure that the gesture cannot be perceived as an attempt to influence the client’s business decisions improperly or allows for an assessment of the gift’s appropriateness to the agency.
Permissible Gestures – Agency
- Branded merchandise such as T-shirts, mugs, notebooks, or pens.
- Personalised thank you notes/Christmas/Birthday Cards
- Invitations to special events, such as VIP parties, product launches, or industry conferences.
- Free or discounted access to workshops, webinars, or seminars relevant to the client’s industry.
- Tours of The Agency’s office or other interesting locations related to the client’s business.
- Office Supplies
- Credit notes or refunds.
- Travel expenses for events or meetings, when necessary.
- Complimentary services or consultations (e.g., landing page, SEO audit).
- Special gifts to mark the anniversary of the client-agency relationship.
- Hosted dinners or lunches.
- Access to online courses or training programs.
- Gift Cards under £50.
Permissable Gifts – Clients
- Small tokens of appreciation such as branded merchandise (e.g., pens, notebooks), occasional meals, or event invitations that are reasonable and proportionate are generally permissible
- Gifts associated with recognised special occasions (e.g., Christmas gifts, retirement gifts) can be accepted, provided they are approved by Senior Management.
Prohibited Gestures/Gifts
- Cash or cash equivalents (e.g., high-value gift cards above £50).
- Lavish or extravagant gifts that could be perceived as an attempt to influence business decisions.
- Any gesture/gift with explicit or implicit expectations of a business favour or advantage.
Responsibilities
Employees: must read, understand, and comply with this policy. Employees are required to report any suspected bribery or corruption.
Management: (including Senior Leadership and Line Managers) must ensure that this policy is communicated and adhered to within their teams. Management should also ensure that any reported incidents are investigated and addressed appropriately.
Reporting Concerns
Employees are encouraged to report any concerns or suspicions of bribery or corruption as soon as possible. Reports can be confidentially made to Senior Management.
Record Keeping
All offers of gifts, hospitality, and expenses must be recorded accurately and transparently in The Good Marketers records. This helps ensure compliance with this policy and relevant laws.
Consequences of Non-Compliance
Non-compliance with this policy can lead to disciplinary action, up to and including termination of employment, and may result in legal action.
Approval and Ownership
This Anti-Bribery Policy has been approved by the Director & Founder and is owned by the Client Success Manager, Paid Media Director, Office Coordinator and Creative Director, who are responsible for its implementation and ongoing maintenance.
Contact Information
For any questions or concerns regarding this policy, please contact:
Tom Wellbourne
Director & Founder
tom@thegoodmarketer.co.uk
