Anti-Bribery & Corruption Policy

Anti-Bribery & Corruption Policy


The Company acknowledges that trust and confidence in the way it carries out its business is essential to its continuing success and relationships with its employees, suppliers and clients.

The Bribery Act 2010 states it is a criminal offence to request, give, offer or receive a financial or other advantage in order to secure a contract or service or to reward improper business activities.


The following policy should be adhered to at all times in everyday business conduct in order to:

  1. protect the reputation of the Company
  2. protect employees from accusations of bribery and impropriety
  3. ensure all clients and suppliers are dealt with on an equal basis
  4. avoid any potential conflicts between employees’ private interests and professional duties.


Employees are not permitted to receive gifts from customers, suppliers or 3rd parties. The exceptions to this are gifts of low value such as promotional pens, calendars and stationery. Likewise, employees are not permitted to offer gifts to customers, suppliers etc, with the intention of securing a business advantage.

Should there be exceptional circumstances when refusing a gift would cause significant embarrassment or offence – ideally the employee should first seek a senior manager’s approval and, if appropriate, the gift should be donated to charity.


Hospitality is deemed to be any form of accommodation, entertainment or other event provided for an employee of the Company by a 3rd party – solely due to his/her position as a representative of the company. Likewise, employees of the company are not permitted to invite customers and suppliers to partake in this form of hospitality with the intent of securing a business advantage.

The following are not considered to be Corporate Hospitality:

  1. Working lunches provided during a business meeting.
  2. Hospitality during a company approved seminar or other external event provided the hospitality is extended to all those present.
  3. Benefit derived from ‘frequent traveller schemes’ such as air miles.
  4. Free seminars and workshops – provided they are not just for the employees of the company.

No hospitality must be accepted prior to approval being granted by the Group Manager.


Bribery and collusion are not limited to Hospitality and Gifts. The Company deems any form of coercion (in order to gain an unfair advantage or for any other purpose) to be wholly unacceptable and will be dealt with very seriously. Attempted bribery (i.e. which is offered but not accepted) is equally unlawful.


Generally, fraud is committed when a person uses deception to gain any kind of financial or personal advantage. In most countries, as in the UK, fraud is considered a criminal offence.

We expect our suppliers to always act honestly and with integrity in their dealings for or with us. We will never seek to gain any advantage fraudulently or allow anybody else to do so on our or their behalf and we similarly expect the same of our suppliers.


Suppliers to IMD should never place their personal interest or gain above that of their employer while performing their work duties and should not seek any personal gain in the fulfilment of their professional duties.

Every employee should avoid all real or apparent conflicts of interest. Employees should avoid any

situation in which they, a member of their family or an acquaintance, would profit or appear to profit

personally from a IMD relationship with its suppliers.


Compliance with this policy is essential to protect the Company and its employees’ reputation. Wilful contravention will be deemed to be bribery

The Company considers it wholly unethical to partake in the act of bribery and collusion of any nature or extent and will consider it to be a serious breach of the employment relationship. It will be considered to be gross misconduct and is likely to result in the termination of employment.

This policy is not solely limited to business transactions in the UK. Any actions of bribery undertaken by an employee of the company abroad will be dealt with in the same manner.

An employee who discovers, or reasonably believes that bribery is about to, or has taken place, must promptly disclose this information to a senior manager so that any appropriate action can be taken. Employees will suffer no detriment for making such a disclosure.

If in any doubt as to whether a transaction may be deemed to be bribery, corruption or a contravention of this policy, employees should seek advice from a senior manager before giving commitment to the transaction.


John R. Allden

Managing Director