RPS Group Plc (RPS) and its subsidiary companies support the UN Global Compact (UNGC) and the UN Convention on Anti-Corruption (UNCAC), the instrument of UNGC’s Principle 10. As such RPS is committed to developing effective anti-corruption policies and programmes.
It is our policy to comply with all relevant anti-corruption legislation and we aim to avoid all corrupt activities. RPS is in a relatively strong position with respect to financial management and early fraud identification among other forms of financial risk. The culture of transparency and the systems of the Group provide a sound basis for financial probity. Within this culture and these systems, there is a high degree of personal accountability and procedural transparency at all levels but relevant procedures involving routine checks have been developed specifically to combat the risk of fraud, bribery and corruption. All staff are made aware of their obligations in regard to avoiding bribery or any other form of corruption, including personal conflicts of interest, either through their terms and conditions of employment, staff inductions or through guidance on avoiding corruption posted on the company’s global intranet.
We define corruption as any form of dishonest or unethical conduct by a person or group of persons to acquire financial benefit or other unmerited advantage for themselves or on behalf of a third party. Corruption includes corrupt facilitation payments, bribery, embezzlement, fraud, money laundering and gross misrepresentation specifically intended to influence the outcome of a selection process or a key decision. RPS seeks to avoid all of these forms of corruption.
RPS expects all staff to conduct business to the highest standards. It is essential that the reputation of the Group is upheld at all times with regulatory bodies, governments, customers, suppliers and all other parties with whom the Group has dealings. All employees, agents and other persons acting on its behalf represent the Group during their normal day-to-day activities and are, therefore, expected to conduct their duties at all times in a professional manner; maintaining rigorous standards of integrity, honesty and conduct, together with adherence to all applicable laws, rules made by any official or regulatory body and Group policies.
Effective risk management comes from the comprehensive identification of risks, followed by a process that assesses the significance of the risk and communicates the issues to senior management. All identified potential risks are reviewed on an individual basis and the level of risk is assessed as to whether they are high, medium or low risk. Low risks are dealt with at office level, medium risks are dealt with at divisional level and high risks are reported to the Group Board.
The Group respects the rights and interests of all its employees. The Group requires its entire staff to adopt the highest standards of behaviour in both their internal and external business dealings and when travelling on business whether within their country of operation or elsewhere. The Group, its subsidiary companies and all its employees are required to comply with the laws and regulations of the countries in which they operate.
All RPS employees are required to avoid personal activities and financial interests, which could conflict with their responsibilities to the Company. Where conflicts of interest arise, they should be openly acknowledged and reported to head office. RPS employees must not seek personal gain, whether financial or non-financial, from third parties nor should they abuse their power within the company for any form of personal gain.
RPS conducts due diligence on new business partners to assess their anti-corruption policies and measures and communicates its relevant policies and measures to them as a compliance requirement. RPS specifically checks for any evidence of professional or financial misrepresentation or corrupt activities within acquisition targets and prospective joint venture partners, professional advisers, agents and intermediaries before it engage in any commercial activities with them.
Staff inductions are routinely conducted via the RPS' intranet where individual staff responses are logged as an integral part of the process. Every page on the Group intranet also has a feedback button that staff are encouraged to use when querying any aspect of policy, procedures or guidance in more detail. Training seminars for staff include live staff interaction with question and answer sessions. New guidance postings on the RPS global intranet are flagged up to staff initially as a pop-up message in the bottom right hand corner of all employee workstations highlighting the subject matter of any new guidance posting.
As regards the history of RPS Group Plc or any of its subsidiaries being subject to relevant fines or prosecutions related to corruption, a former RPS trading subsidiary, RPS Thomson Limited, was prosecuted and fined on 19th March 1999 at Watford Magistrates Court, following an acknowledged oversight in an asbestos survey carried out two years previously at a workshop within Borehamwood Studios, Hertfordshire.
Following an HSE investigation, neither the directors of RPS Thomson Limited, nor its training policy, nor its quality system were found to be at fault by the regulator. A lack of diligence on the part of two former employees was accepted as the cause. Under the circumstances, the HSE did not instruct the magistrate to refer the matter to a higher court and the company's plea of mitigation was accepted. A token fine of £3,000 was imposed and promptly paid.
Anti-Bribery Policy and Procedures
RPS values its reputation for ethical behaviour and financial probity. As part of this the Group operates a zero tolerance policy towards acts of bribery. Penalties for breach of bribery law may comprise imprisonment and fines for individuals as well as substantial fines for the Group. This is in addition to the possible exclusion from future business opportunities and tendering processes as well as the substantial loss of reputation that may be occasioned by a breach of law.
What is Bribery?
Bribery occurs when a person offers, promises or gives a financial or other reward or advantage to another person with the intention of inducing that person to act improperly, or to reward them for doing so. An offence may be committed under anti-bribery legislation not only when a bribe is given but also when it is received. Bribes given on our behalf, by a partner, agent, sub-contractor or other third party with whom we have an association are also likely to constitute an offence. Bribery can include excessive gifts and hospitality, payments made to secure commercial advantage and payments made to officials in order to facilitate certain actions, which they are already duty-bound to perform. Bribery laws will vary by jurisdiction and accordingly differing technical offences and penalties will apply. The general principles contained in this policy are, however, applicable to all countries in which we operate or do business.
Prevention of Bribery
The prevention, detection and reporting of bribery are key priorities for the Group. The Group maintains appropriate financial controls, one of the purposes of which is to detect any unusual payments made to third parties. The prevention and reporting of bribery is, however, the responsibility of all employees. The Group also expects its sub-contractors and agents to follow policies and practices that are consistent with its own policies.
The key obligations of employees under this policy are as follows:
a) under no circumstance to offer, give, solicit or accept a bribe whether by way of cash or other inducement;
b) under no circumstance to encourage or procure any third party to offer, give, solicit or accept a bribe;
c) to promptly report any suspicion of bribery as detailed below;
d) to ensure that our anti-bribery policy is clearly communicated to any suppliers, sub-contractors, agents, partners or intermediaries with whom we are dealing and ensure as far as possible that these parties do not make or take any prohibited payments or inducements on our behalf;
If an employee is ever unsure as to the extent of their obligations or how to proceed in any particular circumstance they must seek advice from their line manager or the Group Company Secretary.
Gifts and Hospitality
This policy is not intended to prohibit gifts or hospitality received or given in connection with our business that are reasonable and limited in terms of value and frequency and are aimed at building relationships. Employees should, however, never offer or accept gifts or hospitality if they might impair objective judgement, improperly influence a decision or create a sense of obligation. Equally employees should never solicit gifts or hospitality or offer or accept gifts of cash or cash equivalent. Employees should use their judgement and common sense in these situations but should, if in any doubt, refer these to their line manager or the Group Company Secretary.
Reporting incidents of Bribery (Whistle Blowing Procedure)
Should employees become aware of an activity that they suspect involves the giving or receiving of a bribe they have a duty to report it. Any suspected activity of this type should be reported to their line manager or may be reported through the Group’s whistle-blowing procedure. In accordance with that procedure matters may be reported to:
Group Company Secretary
RPS Group Plc
20 Western Avenue
Abingdon OX14 4SH
T: +44 (0) 1235 438151
Any referrals through the whistle-blowing process will be treated with appropriate confidentiality.
As indicated above bribery may be a criminal offence in respect of which criminal penalties apply. In addition any breach of this policy will be dealt with in accordance with appropriate disciplinary procedures.