Anti-bribery and corruption.

The UK Bribery Act became law on 1st July 2011 and was enhanced by the Criminal Finances Act 2017 (CFA 2017), with new rules for businesses and individuals in relation to bribery and corruption and tax evasion. Full details can be found in the Anti-Bribery and Corruption Policy.

Bribery is defined as the offer, promise, giving, demanding or acceptance of an advantage as an inducement to perform an action which is unethical, illegal or a breach of trust.

The Directors are committed to ensure that the GardX Group (GardX) and any subsidiary organisations conducts its operations in full compliance with the requirements set out in the UK Bribery Act and will therefore apply a “zero tolerance” approach to any acts of bribery or corruption by any agent, employee, or third-party representative.

 

WHY IS THIS IMPORTANT TO ME?

  • – Unlimited fines for companies
  • – Potential Disciplinary Action
  • – Reputational damage for the company
  • – Up to 10 years imprisonment
  • – Fines for individuals
  • – For more information see the Anti-Bribery and Corruption Policy.
 
 

DO

  • – Get prior, written permission from the Director of Operations, Director of Finance, HR, or the Chief Executive Officer if you want to   make any kind of promotional payment to, or receive reimbursement for, any third party’s travel, meal, or entertainment expenses.
  • – Take particular care when involved in a tender process or during contractual negotiations.
  • – Be aware of the rules when purchasing a new vehicle from a supporting dealer.
  • – Get prior written permission from the Head of Commercial  Operations, Director of Finance, HR, or the Chief Executive Officer if you want to give any kind of token or gift to any other party.
  • – Immediately report any suspected violations of the guidelines to the Director of Operations, Director of Finance, HR, or the Chief Executive Officer, or at the latest within TWO business days.
 
 

DON’T

  • – Make, promise, offer or authorise any payment or gift of anything of value to any other party.
  • – Allow any of the GardX Group business partners, distributors, consultants, or business agents to make a prohibited payment on GardX’s behalf.
  • – Make or authorize any political contributions by GardX, or on its behalf.
  • – Make or authorise any charitable donation using GardX Group assets, whether cash or otherwise. The only GardX person authorised to make or direct such contributions is the Director of Operations, Director of Finance, HR, or the Chief Executive Officer.
 
 

Criminal Finances Act 2017 (CFA 2017)

On 30 September 2017, Part 3 of the UK Criminal Finances Act 2017 (the “CF Act”) came into force creating new corporate offences for failing to prevent the facilitation of UK or overseas tax evasion. 

Similar to the standard set forth for bribery in the UK Bribery Act 2010 (the “Bribery Act”), the new tax offences effectively impose strict liability on a company whose employees are found to have facilitated tax evasion, unless the company can show it had reasonable prevention procedures in place. 

At the same time, the law creates new measures, which are set to come into effect in the near future, aiming to tackle money laundering and corruption, facilitate the recovery of the proceeds of crime and terrorist financing and provide authorities with new investigative and recovery powers. 

It is the latest effort in a global trend among UK, US, and other international regulators to aggressively battle tax evasion, money laundering, and other financial crimes worldwide.

The GardX Group is dedicated to conducting all its activities in a law-abiding and ethical manner and will not tolerate acts of criminal facilitation of tax evasion by its staff, subcontractors, third parties or any other of its associates anywhere in the world. 

The purpose of this policy is to set out the responsibilities of GardX and of those working for it, whether as an officer, employee, worker, subcontractor, agent or in any other capacity, in observing and upholding GardX’s position on criminal facilitation of tax evasion. 

This policy applies alongside GardX’s Anti-Money Laundering Policy, Sanctions Policy and Anti-Bribery and Corruption Policy.

 

COMPLIANCE TO THE BRIBERY ACT AND THE CFA (2017) IS YOUR RESPONSIBILITY – THINK BEFORE YOU ACT!