Kleboe Ltd takes a zero-tolerance approach to bribery and corruption. We do business honestly, or not at all.
Scope
This policy applies to everyone who works for or on behalf of Kleboe, including directors, staff, contractors and associates.
The law
We comply with the Bribery Act 2010, which makes it an offence to offer, give, request or accept a bribe, to bribe a foreign public official, and for a company to fail to prevent bribery. We also comply with the Criminal Finances Act 2017 on the facilitation of tax evasion, and the Economic Crime and Corporate Transparency Act 2023.
What we will not do
- Offer or accept any payment, gift or advantage intended to influence a hiring decision or a business award.
- Pay or accept "introduction fees" or kickbacks from candidates or third parties.
- Make facilitation payments of any size.
- Help any person or organisation evade tax.
Gifts and hospitality
Modest, occasional and proportionate hospitality is part of normal business. Anything over £50, or anything offered during a live search or tender, must be declined or recorded in our gifts and hospitality register.
Third parties
We expect suppliers and associates to share these standards and we carry out proportionate due diligence before working with them.
Raising a concern
Anyone who suspects bribery should report it to enquiries@kleboe.co.uk. We will protect anyone raising a concern in good faith, in line with the Public Interest Disclosure Act 1998.
Responsibility and review
The director of Kleboe Ltd is responsible for this policy and reviews it at least once a year.