Professional Ethics in Construction and Engineering

Appendix A Anti-Bribery Policy

1.1 Purpose

The purpose of this document is to define the Organisation Policy on anti-bribery. The policy is based on the Bribery Act 2010 (‘Act’), which came into force on 1 July 2011, replacing and enhancing fragmented and complex existing laws which date from 1889, 1906 and 1916.

The United Kingdom signed an international treaty in 1998 to combat bribery and corruption and the new Act is intended to ensure that the United Kingdom is compliant with its obligations under that treaty.

The Act applies to offences committed on or after 1 July 2011 and the earlier statutes continue to apply to offences committed before 1 July 2011.

1.2 Scope

1.2.1 To Whom the Policy Applies

This Policy applies to all Members of the Organisation, including subsidiary companies, which means all employees and independent members of Council and its Committees, in particular:

• Members of the Organisation who pay or accept a bribe could be personally prosecuted.
• Senior managers are at risk of prosecution if they ‘turn a blind eye’ to bribes which are paid or accepted by the staff they supervise.

The Policy also applies to students where they are acting on behalf of the Organisation. Either in a paid or in a voluntary role.

It should be noted that ‘Commercial organisations’ can be prosecuted and, in addition to companies and partnerships, this expression is wide enough to include universities, schools and charities.

The Act does not only apply to individuals and commercial ...