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Legals

IQE Limited Anti-Bribery & Corruption Policy

Compliance Policy, Practices & Procedures

This Policy applies to all permanent and temporary employees of IQE (including its subsidiary companies). It also applies to any individual or corporate entity associated with IQE or who performs functions in relation to, or for and on behalf of IQE, including, but not limited to, directors, agency workers, casual workers, contractors, consultants, seconded staff, agents, suppliers and sponsors ("Associated Persons"). All employees and Associated Persons are expected to adhere to the principles set out in this policy.

This document ("The Policy") has been approved by the directors and sets out IQE's position on any form of bribery and/or corruption ("Bribery"). To comply with Isle of Man Bribery Act 2013 ("IOMBA") IQE provides guidelines aimed at:

• ensuring compliance with anti-bribery laws, rules and regulations, not just within the IOM but in any other country within which IQE may carry out its business or in relation to which its business may be connected
• enabling employees and Associated Persons to understand the risks associated with Bribery and to encourage them to be vigilant and effectively recognise, prevent and report any wrongdoing whether by themselves or others
• providing suitable and secure reporting and communication channels and ensuring that any information that is reported is properly and effectively dealt with
• creating and maintaining a rigorous and effective framework for dealing with any suspected instances of bribery or corruption

One of IQE's core values is to uphold responsible and fair business practices. It is committed to promoting and maintaining a high level of ethical standards in relation to all of its business activities. Its reputation for maintaining lawful business practices is of paramount importance and this Policy is designed to preserve these values.

IQE has a zero-tolerance towards Bribery and is committed to acting fairly and with integrity in all of its business dealings and relationships and implementing and enforcing effective systems to counter Bribery, not just within the Isle of Man, but in any other country within which IQE may carry out its business, or in relation to which its business is connected

It is an offence for a "relevant commercial organisation" such as IQE to fail to prevent Bribery. In this context it is liable if any Associated Person commits an act of Bribery whether that person is prosecuted or not.

It is, however, a defence to any such criminal allegation to show, on balance of probabilities, that IQE nevertheless had adequate procedures in place to prevent Associated Persons from undertaking Bribery.

Policy Statement

IQE is committed to running a professional business free from discreditable behaviour.   It is particularly committed to prevent bribery by Associated Persons. All directors and employees are required to:comply with any anti-bribery and anti-corruption legislation in any jurisdiction, wherever they might be expected to conduct business

• act honestly, responsibly and with integrity • safeguard and uphold IQE's core values by operating in an ethical, professional and lawful manner at all times

In order to prevent the unwitting engagement in behaviour which might raise the suspicion of Bribery and to prevent any Associated Person purporting to act on its behalf in a manner that brings suspicion on IQE and its employees, the following measures have been adopted as appropriate and proportionate to the risks it faces.

They will be enforced by their dissemination, regular training and disciplinary measures and will be appropriately resourced

Responsibilities

All Associated Persons are responsible for compliance with this Policy. The Executive Directors and management will exercise oversight, make assessments of risk, deal with decisions where potential for bribery exists, receive and investigate reports of Bribery and supervise the measures put in place to prevent Bribery.

IQE's directors and employees shall report, in accordance with the Company's Whistleblowing Policy, which can be found in the Staff handbook under S2.8, any suspicion of Bribery which comes to their attention, whether it consists of an approach to one of them or an act done by an associated third party

The Company will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken. It is also committed to ensuring nobody suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or corruption offence has taken place or may take place in the future

The Company encourages all employees and Associated Persons to be vigilant and to report any unlawful conduct, suspicions or concerns promptly and without undue delay so that investigation may proceed and any action can be taken expeditiously. Confidentiality will be maintained during the investigation to the extent that this is practical and appropriate in the circumstances.

The Company is committed to taking appropriate action against bribery and corruption. This could include either reporting the matter to an appropriate external government department, regulatory agency or the police and/or taking internal disciplinary action against relevant employees and/or terminating contracts with Associated Persons.

Bribery

A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

It is an offence in the IOM to:

• offer, promise or give a financial or other advantage to another person (i.e. bribe a person), whether within IOM or abroad, with the intention of inducing or rewarding improper conduct
• request agree to receive or accept a  financial or other advantage (i.e. receive a bribe) for or in relation to improper conduct
• bribe a foreign official

Bribery of any kind is strictly prohibited. Under no circumstances should any provision be made, money set aside or accounts created for the purposes of facilitating the payment or receipt of a bribe.

It is also an offence for an employee or Associated Person to bribe another person in the course of doing his business intending either to obtain or retain business or to obtain or retain an advantage in the conduct of business for IQE. IQE can be liable for this offence where it has failed to prevent such bribery by Associated Persons. As well as an unlimited fine it could suffer substantial reputational damage

Corrupton

Corruption is:

•the misuse of entrusted power for private gain.
•the misuse of public power (by elected politician or appointed civil servant) for private gain
•dishonest or fraudulent conduct by those in power, typically involving bribery.

Gifts & Hospitality

IQE has documented procedures in relation to receipt of gifts from third parties and corporate hospitality offered to or received from third parties.  They form part of IQE's zero tolerance policy towards Bribery and they should be read in conjunction with this policy.

Contracts with Clients

IQE has documented procedures in relation to receipt of gifts from third parties and corporate hospitality offered to or received from third parties.  They form part of IQE's zero tolerance policy towards Bribery and they should be read in conjunction with this policy.

Sub-Contracting

In subcontracting professional work to agents no fee should be sought or accepted for awarding a contract to a subcontractor

Charitable & Political Donations

Donations of a charitable or political nature must be approved by the Executive Committee and be subject to due diligence to ensure that there can be no suspicion that any advantage could be thought to accrue to the company or any of its directors or employees

Communication

A copy of IQE's policy will be available on IQE's website. (Reference is also included in our terms and conditions provided to clients, contracts with suppliers and agents).

Training

Directors and employees of IQE will be required to undergo regular training in the terms of the IOMBA and the requirements described in this document. It shall be a term of the contracts of employment that such training should be undertaken.

A copy of the up to date guidance given by the Isle of Man Government is available at http://www.gov.im/about-the-government/departments/home-affairs/legislation/

Any member of staff should be able to approach the directors, Risk Manager or the HR Manager in absolute confidence in order to receive advice as to their conduct or to report a matter of concern which relates to bribery, corruption and whistleblowing.

We have the expertise to assist with multi-jurisdictional fiduciary services for international structures

A breath of fresh air; their professionalism and competence are second to none which when combined with their flexibility, accuracy and work ethic makes IQE a truly first rate organisation. Rupert Cottrell, FCSI,

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