01Purpose and scope
This policy sets out how Legacy Software Limited ("Legacy Software", "we") prevents bribery and corruption, and how we comply with the Bribery Act 2010 and the anti-corruption laws of every country in which we do business.
It applies to everyone who works for us or on our behalf: directors, employees, contractors and consultants, and to the resellers, agents and partners who represent us ("associated persons").
02Our position
Zero tolerance. We do not offer, promise, give, request or accept bribes, directly or through anyone else, whether to or from public officials or private individuals and companies. We would rather lose business than win it improperly.
A bribe is anything of value (money, gifts, hospitality, jobs, favours, donations or confidential information) offered or given to induce or reward someone for acting improperly, or to influence a public official in their role.
Breaching the Bribery Act can lead to unlimited fines for the company and up to ten years in prison for individuals. A company can also be guilty of failing to prevent bribery by anyone acting on its behalf, which is why this policy covers our partners too.
03What is not allowed
- Offering or giving anything of value to win or keep business, or to gain an improper advantage.
- Asking for or accepting anything of value in return for awarding business or acting improperly.
- Facilitation payments: small unofficial payments to speed up routine official actions. They are bribes under UK law, whatever local practice may be.
- Using a third party, such as an agent, reseller or consultant, to do anything this policy forbids.
- Disguising any payment, or keeping records that do not show what a payment was really for.
04Gifts and hospitality
Modest, occasional gifts and hospitality are a normal part of business, provided they are reasonable, proportionate, given openly and not intended to influence a decision.
- Never give or accept gifts or hospitality during a tender or contract negotiation with the other party.
- Never give or accept cash or cash equivalents, such as vouchers.
- Any gift or hospitality worth more than £100, given or received, needs a director’s approval beforehand and is recorded in our gifts and hospitality register.
- Respect the rules of the other organisation: many of our customers, especially in the public sector and financial services, have stricter limits than ours.
05Public officials, donations and sponsorship
We take particular care in dealing with public officials and state-owned organisations. We make no political donations. Charitable donations and sponsorship are made openly, approved by a director, and never connected with winning business.
06Partners, resellers and suppliers
We choose our resellers, integration partners, agents and suppliers carefully. Before we appoint anyone to act on our behalf we check who they are and their reputation, and our agreements require them to comply with anti-bribery law and this policy. Commission and fees are paid only for legitimate services, at rates that reflect the work done, and are properly documented.
We will end a relationship with anyone who does not meet these standards.
07Records and controls
We keep accurate books and records of every payment, invoice, expense claim, gift and item of hospitality. All expenses are approved before they are paid. Our accounts are prepared and reviewed independently.
08Responsibilities and training
The directors are responsible for this policy and for making sure it is followed. Everyone covered by it is responsible for reading and following it, and for asking if they are unsure. New staff are briefed on it when they join, and everyone is reminded of it every year.
09Raising a concern
Anyone can raise a concern, in confidence, with a director or by email to support@legacysoftware.co.uk. We will look into every concern raised in good faith, and nobody will suffer any detriment for raising one, even if it turns out to be mistaken.
If you are offered a bribe, or asked to make one, decline it and tell a director straight away.
10Breaches of this policy
Anyone who works for us and breaches this policy may face disciplinary action, which could lead to dismissal for gross misconduct. We may end our relationship with any partner or supplier who breaches it, and we will report wrongdoing to the authorities where appropriate.
Approved by the directors of Legacy Software Limited. This policy is reviewed every year, and sooner if the law or our business changes.