Anti-Bribery & Anti-Corruption Policy

1. Policy Statement

Vensa Technology is committed to conducting business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships wherever we operate.

We are bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct both at home and abroad.

2. Who is Covered by the Policy?

This policy applies to all individuals working at all levels, including senior managers, officers, directors, employees (whether temporary or permanent), consultants, contractors, trainees, homeworkers, casual staff, and agency staff (collectively referred to as "Staff"). It also applies to our agents, suppliers, and any other person associated with us.

3. What is Bribery?

A bribe is a financial or other advantage offered, promised, or given to someone to persuade them to perform a function or activity improperly, or to reward them for having done so. Specifically, it is an offence to:

  • Give or offer a bribe: Promising a reward to a client or contact to influence their business decision.
  • Receive or request a bribe: Accepting a gift or "kickback" in exchange for preferential treatment of a candidate or supplier.
  • Bribe a foreign public official: Offering incentives to government officials to facilitate business.
  • Fail to prevent bribery: A corporate offence where a company does not have adequate procedures to stop bribery.

4. Gifts and Hospitality

This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties. However, hospitality and gifts must:

  • Be reasonable, proportionate, and for a legitimate business purpose.
  • Not be made with the intention of influencing a third party to obtain or retain business.
  • Comply with local law.
  • Be declared in our Gifts and Hospitality Register (where the value exceeds £50).

5. Facilitation Payments and "Kickbacks"

We do not make, and will not accept, facilitation payments or "kickbacks" of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action. All staff must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.

6. Recruitment Specific Risks

We recognise that certain practices in the recruitment industry carry higher risks. Vensa Technology prohibits:

  • Offering incentives to a client’s employees to bypass their official procurement processes.
  • Accepting "referral fees" from umbrella companies or payroll providers that have not been transparently disclosed and approved.
  • Inflating candidate salaries or day rates specifically to increase commission through unethical agreements.

7. Record-Keeping

We keep financial records and have appropriate internal controls in place which will evidence the