Anti-Bribery Policy

1. Policy Statement

Pest Pulse Limited, trading as "Pest Pulse", is committed to conducting its business with honesty, fairness and integrity. We expect everyone working on behalf of Pest Pulse to maintain the highest ethical standards, and we want our staff to report any suspicions of wrongdoing. Pest Pulse takes a zero-tolerance approach to bribery and other forms of corruption. Pest Pulse actively promotes a culture where bribery and corruption are never acceptable.

2. Purpose

This policy sets out Pest Pulse’s position on bribery and corruption and provides information and guidance to those working for Pest Pulse on how to recognise and deal with bribery and corruption issues. This policy relates to the following statutory obligations:

  • Bribery Act 2010 (UK);
  • Public Interest Disclosure (NI) Order 1998 (NI);
  • Public Interest Disclosure (Prescribed Persons) (Amendment) Order (Northern Ireland) 2014 (NI);
  • Ethics in Public Office Act 1995 (RoI);
  • Standards in Public Office Act 2001 (RoI);
  • Criminal Justice Act 2011 (RoI);
  • Prevention of Corruption (Amendment) Act 2010 (RoI);
  • Protected Disclosures Act 2014 (RoI);
  • Companies Act 2014 (RoI);
  • Regulation of Lobbying Act 2015 (RoI);
  • Criminal Justice (Corruption Offences) Act 2018

3. Scope

This policy applies to all individuals working at all levels and grades within Pest Pulse, consultants, contractors, trainees, seconded staff, or any other person associated with Pest Pulse.

This Policy covers Pest Pulse and its operating companies and businesses and any of its subsidiaries in any geographic region. This policy applies to all Board members and individuals working at all levels and grades within Pest Pulse including part-time, full-time, casual workers, consultants, contractors, trainees, seconded staff, or any other person associated with Pest Pulse.

4. Definitions

"Bribe" means any advantage whether monetary or other form, including but not limited to, undue influence, receipt of favours and corruption.

"Corruption" is an abuse of power that involves acting dishonestly or improperly in return for money, personal gain, or anything of value.

5. Gifts & Hospitality

The act of exchanging business gifts and receiving corporate hospitality can play an appropriate role in building or maintaining business relationships.

This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties. Further, the giving or receipt of gifts is not prohibited if the following requirements are met:

  • it is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits
  • it does not include cash or a cash equivalent (such as gift certificates or vouchers);
  • taking into account the reason for the gift, it is of an appropriate type and value and given at an appropriate time: for example, it can be customary for small gifts to be given at Christmas; and
  • it is given openly, not secretly.

However, gifts and hospitality are problematic if they create actual or perceived conflicts of interest, or otherwise appear to influence a business decision.

It is not acceptable for you (or someone on your behalf) to:

  • give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
  • give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to facilitate or expedite a routine procedure;
  • accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them;
  • accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by Pest Pulse in return
  • threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or
  • engage in any activity that might lead to a breach of this policy.

6. Donations

Charitable contributions may only be given to recognised non-profit charitable organisations. All donations must be:

  • transparent and properly recorded in our books and records;
  • receipted or have a letter of acknowledgement from the charity to ensure that the donations receive the proper tax treatment; and
  • be compliant with local laws and regulations.

Donations must not be made to individuals or in cash.

Pest Pulse is not a political organisation. It does not support political parties and does not make contributions to political parties.

7. Recordkeeping

Pest Pulse keeps financial records and has appropriate internal controls in place which show the business reason for making any and all payments to third parties. All expense claims relating to hospitality, gifts or expenses incurred must be submitted in accordance with Pest Pulse’s expenses policy and specifically record the reason for the expenditure. All accounts, invoices and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, are prepared and maintained with strict accuracy and completeness. No accounts are kept "off-book" to facilitate or conceal improper payments.

8. Responsibilities

The Pest Pulse board of directors has overall responsibility for ensuring this policy complies with Pest Pulse’s legal and ethical obligations. Pest Pulse’s Chief Executive Officer is responsible for communication of the policy to all new staff during induction.

You must ensure that you read, understand and comply with this policy. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy. Employees are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. No employee will suffer any detriment as a result of raising genuine concerns about bribery, even if they turn out to be mistaken.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Pest Pulse reserves its right to terminate its contractual relationship with other workers if they breach this policy.

9. Monitoring & Review

The effectiveness of this policy will be regularly reviewed by the Pest Pulse board of directors. Internal control systems and procedures will be subject to audit under the internal audit process.

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