It is the policy of CVS Group plc and its group companies (“CVS”) to conduct business in an honest and ethical manner. As part of that, CVS takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships, wherever it operates, and implementing and enforcing effective systems to counter bribery.
CVS will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which it conducts business, including, in the UK, the Bribery Act 2010 (the Act), which applies to conduct both in the UK and abroad.
This policy applies to all individuals working for or on behalf of CVS at all levels and grades, whether permanent, fixed-term or temporary, and wherever located, including consultants, locums, contractors, casual staff, agency staff, volunteers, agents, sponsors and any other person who performs services for or on behalf of CVS (all “CVS Representatives”).
In this policy, Third Party means any individual or organisation that CVS Representatives come into contact with during the course of work and the running of CVS’s business, and includes actual and potential clients, intermediaries, referrers of work, suppliers, distributors, business contacts, agents, advisers, government and public bodies (including their advisers, representatives and officials), politicians and political parties.
A bribe is an inducement or reward offered, promised or provided in order to improperly gain any commercial, contractual, regulatory or personal advantage, which may constitute an offence under the Act, namely:
CVS may also be liable under the Act if it fails to prevent bribery by an associated person (including, but not limited to CVS Representatives) for CVS’s benefit.
This policy does not prohibit normal and appropriate gifts and hospitality (given and received) to or from Third Parties unless otherwise specifically stated. However, we have specific internal policies and procedures which provide guidance to CVS Representatives as to what is to be regarded as normal and appropriate gifts and hospitality in terms of financial limits, subject to the principles set out below (the Overriding Principles), namely that any gift or hospitality:
CVS appreciates that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable both in the UK and any other relevant country. The intention behind the gift should always be considered.
It is not acceptable for any CVS Representative (or someone on their behalf) to:
We do not make, and will not accept, facilitation payments or “kickbacks” of any kind, such as small, unofficial payments made to secure or expedite a routine government action by a government official, or payments made in return for a business favour or advantage.
CVS only makes charitable donations and provides sponsorship that are legal and ethical under local laws and practices and which are in accordance with CVS’s internal policies and procedures.
We keep appropriate financial records and have appropriate internal controls in place which evidence the business reason for gifts, hospitality and payments made and received.
The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for CVS or under our control. All CVS Representatives are required to avoid any activity that might lead to, or suggest, a breach of this policy.
CVS Representatives are required to notify CVS as soon as possible if it is believed or suspected that a conflict with this policy has occurred, or may occur in the future, or if they are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that they are a victim of another form of unlawful activity.
Any CVS Representative who breaches this policy may face disciplinary action, which could result in dismissal for gross misconduct. CVS reserves all rights to terminate contractual relationships with non-employee CVS Representatives if they breach this policy.
If any Third Party is aware of any activity by any CVS Representative which might lead to, or suggest, a breach of this policy, they should raise their concerns with any member of CVS’s Human Resources Team or the Company Secretary at company.secretary@cvsvets.com.
CVS monitors the effectiveness and reviews the implementation of this policy at appropriate intervals, considering its suitability, adequacy and effectiveness. Any improvements identified are made as soon as possible.
