GPW + Co Ltd [GPW] applies the highest ethical standards across its operations. This guiding principle includes an uncompromising stance on bribery.
We commit to applying consistently the letter and spirit of applicable anti-bribery legislation in all markets and jurisdictions in which GPW operates, including, but not limited to, the UK Bribery Act 2010. Our zero tolerance policy with respect to the giving or receiving of bribes includes the making of facilitation payments and is clearly communicated to all employees and all relevant third parties.
Specifically, GPW’s anti-bribery policy prohibits employees, contracted staff, advisers and consultants from, directly or indirectly, offering, promising or receiving any bribe, financial or other advantage, making any payment or transfer for value, or other inducement in any form, which has the purpose or effect of public or commercial bribery. GPW also prohibits acceptance of, or acquiescence in, bribery, extortion, facilitation payments or other unlawful or improper means of obtaining or retaining any business or commercial advantage or bringing about the improper performance of any person’s business or public function or activity. This prohibition applies to third parties who are retained to perform services or conduct business for and on behalf of GPW, or those conducting business together with GPW (including, but not limited to our agents, representatives, intermediaries, introducers, brokers, contractors, suppliers, consultants and joint venture entities) [‘third parties’].
We require all employees and third parties to comply with the following principles in the performance of their services for or on behalf of GPW:
Bribery and facilitation payments: All forms of bribery, including facilitation payments (except in order to protect against loss of life, limb or liberty), are prohibited, whether they take place directly or indirectly through another party.
Public officials: Dealings involving public or government officials require heightened care, diligence and transparency, as well as a need for appropriate disclosures and approvals.
Political contributions: Funds, property or facilities of GPW must not be used to provide support for, or contribute to, any political organisation or political candidate.
Charitable contributions and sponsorships: Charitable contributions and sponsorships must not be used as subterfuge for bribery.
Gifts and hospitality: GPW’s employees must not offer or accept any gifts or inducements (personal benefits) to or from any person which are likely to conflict with their duties to any client or GPW office. We have similar expectations of our third parties.