Anti-Corruption Policy

  1. ANTI-BRIBERY AND ANTI-CORRUPTION POLICY STATEMENT
    1. Gama Electronics (Gama) is committed to conduct all business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships.
  2. WHO MUST COMPLY WITH THIS POLICY?
    1. This policy applies to all persons working for Gama or on their behalf in any capacity, including employees at all levels, directors, contractors, external consultants, third-party representatives and business partners.
  3. WHAT IS BRIBERY?
    1. A “Bribe” means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust, or improper in any way. Bribes can take the form of money, kickback, gifts, loans, fees, hospitality, services, discounts, the award of a contract, or any other commercial or personal advantage or benefit.
    2. “Bribery” includes offering, promising, giving, accepting or seeking a bribe.
    3. All forms of Bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it immediately with your manager.
    4. Specifically, you must not:
      • give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received.
      • accept any offer from a third party that you know or suspect is made with the expectation that will provide a business advantage.
      • give or offer any payment to facilitate an advantage.
      • Make threats against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.
  4. WHAT IS CORRUPTION?
    1. “Corruption” means inducing or committing dishonest or fraudulent conduct to gain advantage. Typically involving persons in positions of power or influence. Corruption can involve bribery or other inducements to facilitate actions which are illegal, unethical, a breach of trust, or improper in any way
  5. GIFTS AND HOSPITALITY
    1. This policy does not prohibit giving or accepting reasonable and appropriate hospitality (including meals, drinks, or other activities) for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.
    2. Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. In general, the gifts should not exceed £25.
    3. Gifts or hospitality will be inappropriate if they are unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment Gifts must not include cash or be given in secret. Gifts must be given in Gama’s name and not in a personal name.
    4. Promotional gifts of low value such as pens, bags, shirts, hats, or other low value branded articles may be given to or accepted from existing customers, suppliers and business partners.
  6. RECORD KEEPING
    1. A written record of all hospitality or gifts given or received will be kept. The account will record the reason for expenditure or Gift.
    2. All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.
  7. WHO IS RESPONSIBLE FOR THIS POLICY?
    1. The Managing Director has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those that come under its control comply with it.
    2. The Managing Director of Gama has primary responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and reviewing internal control systems and procedures to ensure they are effective in countering bribery and corruption.
    3. All employees of Gama are responsible for ensuring compliance with this policy.
    4. This policy will be reviewed regularly and we may amend it at any time to update with best practices and processes.
  8. YOUR COMPLIANCE WITH THIS POLICY
    1. All employees must read and ensure that they understand and comply with this policy.
    2. Preventing, detecting, and reporting bribery in any part of our business or supply chains is the responsibility of all employees  working for Gam or under Gama control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
  9. HOW AND WHEN TO NOTIFY IN CASE OF NON-COMPLIANCE
    1. If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur in the future, you must notify your manager immediately.
    2. You are encouraged to raise concerns about any issue or suspicion of bribery in any parts of our business or supply chains at the earliest possible stage.
    3. If you are unsure about whether a particular act constitutes any of the various forms of bribery, raise it with your manager.
    4. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that bribery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Managing Director immediately.
  10. COMMUNICATION AND AWARENESS OF THIS POLICY
    1. Our commitment to addressing issues of bribery in our business and supply chains should be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
  11. BREACHES OF THIS POLICY
    1. Any employee who breaches this policy may face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
    2. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
    3. We may terminate our relationship with present or future customers if they breach this policy.

Download as a PDF: Gama Electronics – Anti-Corruption Policy