Anti-bribery &
Anti-corruption

Policy and Procedure

Policy Statement 

twentyfifty Ltd. (“twentyfifty”) prides itself on its transparent, ethical, open, and honest business practices.  twentyfifty complies with the (UK) Bribery Act 2010 as amended (“the Act”) and any other relevant laws in the jurisdictions it operates in including the FCPA in the USA (“Applicable Laws”). twentyfifty does not tolerate any forms of bribery and corruption within its own operations or by its associates or clients.

1. Who is covered by the policy

This policy applies to employees, directors, and associates (collectively known as “personnel”). 

2. What is bribery?

Bribery can be broadly defined as the receiving or offering/giving of any benefit (in cash or in kind) by or to any public servant or office holder or to a director or employee of a private company in order to induce that person to give improper assistance in breach of their duty to the government or company which has employed or appointed them. Bribery and corruption can be direct or indirect and can involve third parties.

3. Gifts and Hospitatity

twentyfifty’s personnel shall not use the company’s funds to induce others to act improperly through the use of gifts and hospitality. Nor shall they accept benefits to be used for improper purposes.

Personnel shall comply with the Act and the Applicable Laws at all times. 

Expenditure on promotional entertainment is not an offence under the Act if people are not induced to act in a way that is improper. A “gift” should not be an inducement to act in a certain manner, therefore, expenditure must be “sensible and proportionate”. If it is beyond sensible and proportionate, then there is a danger it may become illegal under the Act and or the Applicable Laws. Hospitality will generally be bona fide where it is provided in order to better present twentyfifty’s image, products, services, or people or to establish cordial relations.

“Sensible and proportionate” will depend on the person and circumstances and what is perceived as normal in the circumstances.

Factors to consider when deeming whether a gift or hospitality is “sensible and proportionate” include:

  • the timing of when the gift is given or received. If it is given during contract negotiations, then it could be perceived to be given to induce an improper result
  • the frequency of gift giving. If it is constant, then it could be deemed as inappropriate
  • how extravagant the gift or hospitality is, the more extravagant the less likely it is perceived to be for any legitimate purpose.

All gifts and hospitality given or received should be noted down on the Gifts and Hospitality Register which can be found at twentyfifty General – HR

4. Conflict of Interest

In the regular course of business, twentyfifty employees and associates may have the opportunity to advance their own personal interests with or against the interests of the company. Acting in such a manner is unacceptable and any party who acts outside of twentyfifty’s best interest may be subject to disciplinary action.

a) Duty to disclose

Every employee/agent (owner, director, stakeholder or contractor) of twentyfifty is obligated to disclose any known or potential conflicts of interest as soon as they arise. Failure to do so could result in termination of employment.

b) Investigating potential conflicts

When a possible conflict of interest arises, the board of directors will collect all of the pertinent information and may question any concerned parties. If the board determines that a conflict exists, steps will be taken to address the conflict. If no conflict exists, the inquiry may be documented but no further action will be taken.

c) Addressing conflicts of interest

When an actual conflict of interest is found, any transactions that may have been affected will be reviewed retroactively. Affected parties both within and outside of the business, including shareholders, directors, employees, and contractors will be notified. An investigation will also be conducted by the board of directors to determine the extent of the conflict and the intentions of the parties involved.

If the conflict in question involves a member or members of the board of directors, such a member will be excused from the deliberations.

d) Disciplinary action

As all conflicts of interest will be reviewed on a case-by-case basis, a review may result in disciplinary action. The board of directors has full discretion to deem what disciplinary action is both fitting and necessary, including suspension and/or termination of employment.

5. Facilitation Payments and Kickbacks

twentyfifty will not authorise any facilitation payments or kickbacks to speed up any official processes.

Facilitation payment and kickbacks are payments, usually made to government officials that speed up official processes. Under the Act all facilitation payments, no matter how small, are illegal and personnel should make it clear that this is a key policy that the company follows and will not move from.

6. Payments to Protect Safety and Life

Staff who face implicit or explicit threats to their health and safety while undertaking the company’s business are permitted to make payments to protect themselves. These payments must be recorded in accounts as “extortion payments” and must be reported to the CEO as soon as possible. Personnel must report such incidents to the company in a timely manner.

7. Staff Responsibilities 

Staff have a responsibility to ensure that:

  • they do not accept or make an offer of gifts that would result in them or a third party taking improper actions
  • if they are in a position where they are offered a bribe, that they disclose it to the company as soon as practicable
  • nothing of value is given or offered to a public official
  • they comply with the company’s guidelines and authorisation levels in relation to gifts and hospitality
  • no facilitation payments are made to government officials to speed up, or make official processes smoother
  • they do everything in accordance with the relevant laws
  • all expenses are clearly reported in accordance with company procedures and guidelines.

Personnel who do not follow these practices may be liable to disciplinary action, dismissal, or legal proceedings.

8. Donations

From time to time, the company may make charitable donations to a certain cause. These payments should be transparent and properly recorded. The organisations receiving the donations should have their own high standards of transparency and accountability and serve a legitimate public purpose. twentyfifty does not make donations to political parties.

9. Record-Keeping

Record-keeping for any of the above-mentioned payments should be properly recorded in accounts and the circumstances of the transaction should be made clear. Payments to third parties for any purchases should be recorded (this includes payments to Associates).

10. What to do if you are a victim of bribery and corruption

Staff who are victims of bribery or corruption should report the incident to the Chief Executive as soon as practicably possible.

11. Protection

Staff who openly report any instances of bribery or corruption in a timely manner shall be protected.

12. Training and Communication

Our zero-tolerance policy to bribery and corruption should be communicated to all personnel and business partners. 

Personnel will be required to read and acknowledge this policy. If there are any questions or queries in relation to this policy it is up to staff members themselves to flag this with the Chief Executive for clarification. 

13. Who is responsible for this policy

The Board of Directors are responsible for the review and communication of this policy.

14. Monitoring and Review

The policy will be reviewed annually, by Directors with the input of other personnel.

15. Due Diligence

twentyfifty will conduct due diligence when:

  • Appointing new business partners, and
  • Before travelling for business to high-risk areas.

Due diligence will include as a minimum, desk-based research from respected sources, such as

Transparency International and the Overseas Business Risk Countries portal set up by UK Trade and Investment, as well as on-the-ground research through business contacts. twentyfifty will also undertake a search for persons/companies through Guarancie (http://www.garancie.com/).

Staff members should also undertake due diligence if and when conducting business in another country. This includes seeking advice from fellow colleagues who have been in the country before about conditions on the ground and any red flags that they may encounter.