COMMITMENTS AND EXPECTATIONS
_SIEGUS® is an Organisation that:
• shall uphold all UK legislation relevant to countering fraud, bribery and corruption, including the Bribery Act 2010
• requires employees and persons working on our behalf to act at all times with honesty, integrity, propriety and due care in all matters, but particularly in the safeguarding of the Organisation, its associated assets and its reputation and that of its parent
• strictly prohibits and will not tolerate fraud, acts of bribery or any other form of corrupt behaviour
• understands and regularly assesses the nature and extent of risks relating to fraud, bribery and
corruption
• ensures by appropriate due diligence that those it does business with share the culture of intolerance to fraud, bribery and corruption
• maintains and clearly communicates its expectations through the Code of Responsible Business Conduct, Company Policy and, for employees, the Terms & Conditions Manuals
• dedicates sufficient resources to implement and embed procedures and to provide anti-fraud, bribery and corruption training
• ensures that practical, cost effective controls and procedures are implemented to proactively identify fraud, bribery and corruption or the threat of fraud, bribery and corruption
• formulates and requires adherence to control processes designed to prevent and detect fraud, acts of bribery and corruption
• remains alert to the risk of fraud, bribery and other irregularities both within the organisation and in organisations with which the organisation contracts and reports any matters of potential concern
• recognises that signs of fraud, bribery and corruption in the organisation and/or its supply chain could be an indication of other illegal or unethical activity, such as modern slavery and/or human trafficking
• promotes an open, honest and questioning culture which encourages propriety and vigilance amongst all personnel.
• maintains an effective Bribery, Corruption and Fraud Response Plan and ensures any matters of suspected or actual bribery, corruption or fraud are dealt with under this Plan, overseen or led by Internal Audit
• implements a process that encourages all personnel to raise any matter of genuine concern, including to an independent organisation who will treat the call with discretion and confidentiality