Our Anti-Fraud & Anti-Corruption Policy and Gifts & Hospitality Policy reflect our determination to maintain the company’s reputation of working to the highest ethical standards and ensuring compliance with legislation, including the Bribery Act 2010.
Smith & Ouzman Ltd has an on going commitment to our Corporate Social Responsibility and recognise the importance of undertaking ethical business practices, ensuring the health and safety, well being and training of our employees, controlling our impact on the environment, and having a positive impact on the society and communities that we work within.
We undertake to achieve this by working with our customers, employees, suppliers, business partners, communities and other stakeholders to act on our responsibilities by working within our core business principles:
- We recognise that our social, economic and environmental responsibilities to our stakeholders are integral to our business. We aim to demonstrate these responsibilities through our actions and within our company policies.
- We take seriously all feedback that we receive from our stakeholders and, where possible, maintain open dialogue to ensure that we fulfil the requirements outlined within this policy.
- We shall be open and honest in communicating our strategies, targets, performance and governance to our stakeholders in our continual commitment to sustainable development.
- We are committed to full legal compliance in all that we do.
- We aim to provide a safe, fulfilling and rewarding career for all our employees.
- We actively assess and manage the environmental impacts of all our operations.
- We will further develop our standing as a responsible business in the community.
- We strive to support local, national and international causes where we have a business presence.
- We will benchmark and evaluate what we do in order to monitor our outputs against our targets and objectives.
- We will operate in a way that safeguard against unethical or unfair business practices.
Smith & Ouzman’s policy is to continually seek to minimise any negative environmental impact from the pursuit of its various business interests whilst continuing to produce high quality product to its customers’ needs, specification and satisfaction.
To achieve this policy Smith & Ouzman operates an Environmental Management System to the requirements of BS EN ISO 14001:2004.
To this end the benefits of our products must be weighed against any environmental impact as a result of their manufacture, sale and ultimate disposal.
All employees are to carry out operations so that, as far as is reasonably practical, the environment and Health & Safety of any one person will not be adversely affected.
Environmental impact is therefore considered throughout the organisation in relation to:
- Design and development of new products and processes;
- Selection of raw materials and suppliers thereof;
- Internal production methods, with particular emphasis on:
- Raising awareness and encouraging participation from employees on reducing pollution, emissions and waste
- Reducing the use of raw materials, energy and supplies
- Minimising and controlling hazardous substances
- Optimising packaging of raw materials and finished products
- Keeping grounds/car parks actively maintained to protect wildlife
It is the Company’s policy to comply with and aim to improve upon all statutory environmental requirements and to foster an informed and open approach to environmental concerns.
The involvement of our employees, customers, suppliers, local communities/authorities will be encouraged to assist us in the achievement of this policy and in continually seeking to improve environmental performance.
It is the Policy of the Company that every possible step will be taken to ensure the Health and Safety at Work of all its employees. In order to carry out this Policy, the following major hazards are recognised and training at all levels will be organised so that these may be avoided:
- Risk from fire
- Contamination of persons by chemicals
- Danger from machinery, guillotines, etc. o Electrocution
- Risk from lack of hygiene
- Non-compliance with building regulations o Everyday accidents
- Risk from general untidiness
Management at all levels shall ensure their responsibility for Health and Safety within their own departments, as with any other of their duties and functions within the Company.
Equally, it is the duty of every employee to take all reasonable steps to care for the Health and Safety of themselves and their fellow workers and any other person who may be on the Company’s premises for any purpose whatsoever. Where Health and Safety regulations are imposed by the Company and/or by Law, it is the duty of all employees to comply with such regulations and report any risk or breach of regulations to the Manager of the Department. Protective Shoes, Clothing and Equipment are made available to staff where there is risk to their personal Health and Safety. Whilst the Company cannot enforce the use of these items, the Company recommend their use at all times. Employees choosing to ignore this recommendation may be subject to disciplinary action.
A Safety Director and a Safety Management representative will be appointed by the Company. The Safety Director will be responsible to the Board of Directors for the effective and efficient organisation and maintenance of Health and Safety within the Company.
A Safety Committee will be set up and will consist of the Safety Director, Management Safety Representative, Union Representative(s) and such other members as the Health and Safety Committee shall from time to time decide.
Specific duties are detailed in separate schedules.
1.1 Smith & Ouzman Ltd (“the Company”) will not tolerate fraud, corruption or abuse of position for personal or corporate gain, wherever it may be found in any area of Company activity.
1.2 The purpose of this Policy is to set out for all Directors, Management, employees, third party agents and representatives, customers, suppliers and stakeholders the main principles for countering fraud and corruption. The policy links closely to the Company’s strategic objectives and supports the Company’s values of security, integrity and reliability.
1.3 The Policy includes:-
o The scope;
o The culture and the stance against fraud and corruption;
o How to raise concerns and report malpractice;
o The principle of having a company anti-fraud & corruption strategy; o The responsible officer.
1.4 The Board of Directors play a key role in counter-fraud and counter-corruption initiatives. This includes providing a corporate environment within which counter-fraud and counter-corruption arrangements will flourish, and the promotion of an anti-fraud and anti-corruption culture across the whole of the Company. This should provide a sound defence against internal and external malpractice.
1.5 Part of the Company’s professional advisors duties is to ensure that the Company has in place adequate arrangements for the prevention and detection of fraud and corruption.
2. Definition of Fraud & Corruption
2.1 The Chartered Institute of Public Finance and Accountancy (Cipfa) defines Fraud as the;
“intentional distortion of financial statements or other records by persons internal or external to the organisation, which is carried out to conceal the misappropriation of assets or otherwise for gain.”
The Fraud Act 2006 further defines fraud in three classes
o False representation
o Failure to disclose information where there is a legal duty to do so o Abuse of position
2.2 Cipfa defines Corruption as the “offering, giving, soliciting or acceptance of an inducement or reward which may improperly influence the action of any person.”
2.3 The Theft Act 1968 defines theft as;
“a person shall be guilty of theft if he dishonestly appropriates property belonging to another with the
intention of permanently depriving the other of it.”
3.1 The Policy applies to Directors, Management, employees, third party agents and representatives, and all persons (full time, part time, temporary and casual) who work for the company.
3.2 The Company expects that individuals and organisations (e.g. partners, suppliers, contractors, service providers, agents and representatives in the UK and overseas) that it deals with will act with integrity and without thought or actions involving fraud and corruption. Where relevant, the Company will include appropriate clauses in its contracts about the consequences of fraud, bribery and corruption; evidence of such acts is most likely to lead to a termination of the particular contract and may lead to prosecution.
3.3 The Anti-Fraud & Corruption Policy is commended to the Company’s partner organisations, with the expectation that they will be applied either wholly or as the basis for their own local version.
3.4 Our Anti-Fraud and Anti-Corruption Policy reflects the Laws and Regulations applicable to the UK and as derived from the United Nations (UN) and Organisation for Economic Co-operation and Development (OECD) conventions on corruption.
3.5 The scope of this Policy is applied to the Company’s activities in the UK and overseas. Contracts undertaken overseas with customers, suppliers as well as third party agents and representatives must also comply with their local anti-fraud and corruption legislation.
4. Culture and Stance Against Fraud & Corruption
4.1 Responsibility for an anti-fraud and anti-corruption culture is the joint duty of the Directors who provide the strategic direction to the Company, Management, and all employees, as well as third party agents and representatives. The strategy should be directed against fraud and corruption whether it is attempted against the Company, its supply chain partners, customers or other third party, from outside or from within its own workforce.
4.2 The Company expects that Directors, Management, and Employees, including third Party agents and representatives, at all levels will lead by example in ensuring adherence to this Policy, legal requirements, codes of conduct and best practice.
4.3 As part of this culture, the Company will provide clear routes by which concerns can be raised by employees of all levels, supply chain partners, customers or other third party.
4.4 Senior Management is expected to deal swiftly and firmly with those who commit any fraudulent or corrupt act. The company will be robust in dealing with malpractice.
4.5 The Company shall have in place a Committee comprising Finance Director, Sales Director and Managing Director, inclusive of an independent legal professional advisor, whose role is relevant and effective in monitoring standards of conduct and financial payments. The Committee shall meet at least annually, and shall ensure that adequate arrangements are established and operating to deal with situations of suspected or actual wrongdoing, fraud and corruption.
5. Raising Concerns
5.1 Although this document specifically refers to fraud and corruption, it equally applies to any forms of malpractice that can reduce confidence in the Company, its services and reputation, and may also include acts committed outside of official duties but which impact upon the Company’s trust in the individual concerned. Examples may include the criminal acts of theft of “property”, which includes all assets and cash; false accounting; obtaining by deception; pecuniary advantage by deception; computer abuse and computer crime. Also, it includes bribery and corruption. “Pressures” can be applied from a number of sources including, customers, suppliers, competitors, the public etc. to act in a particular way in a particular case; this may involve “favouritism” regarding the provision or access to various benefits (e.g. commission structures, rebates, contract award and pricing, etc.).
5.2 Company employees are an important element in the company’s stance on fraud and corruption, and they are positively encouraged and directed to raise any concerns that they may have on these issues where they are associated with the Company’s activity.
5.3 Employees should normally raise concerns thorough their immediate manager, however it is recognised that they may feel inhibited in certain circumstances. In this case, employees should contact one of the Company Directors.
6. Action the Company Will Take
6.1 All concerns will be treated in confidence and will be investigated promptly and fully in a professional manner. It should be noted that an allegation does not mean the individual person or company is guilty of any wrong-doing, and so they will not be treated as such until the case is proven.
6.2 If fraud or corruption has taken place, the Company will, in appropriate cases:
o Refer the case to the police and other relevant regulator authorities;
o Take appropriate disciplinary action where it involves an employee and this may lead to dismissal; o Pursue recovery for any financial loss.
6.3 There is, of course, a need to ensure that the investigation process is not misused, therefore, any internal abuse, such as raising malicious or vexatious allegations, may be dealt with as a disciplinary matter.
7. Anti-Fraud & Corruption Strategy
7.1 This Policy also forms an important part of the Anti-Fraud & Corruption strategy by setting out the tone, culture and expectations of the Company, as part of the corporate framework.
7.2 The Company is concerned with both operational activity to detect and investigate fraud and corruption and also pro-active actions to deter and prevent fraud and corruption through the development of an anti-fraud and corruption culture.
7.3 The Company’s Anti-Fraud and Anti-Corruption Policy requires Employees:
o Not to offer or make any bribe, unorthodox or unauthorised payment or inducement of any kind to anyone;
o Not to solicit business by offering any bribe, unorthodox or unofficial payment to customers or potential customers;
o Not to accept any kind of bribe, unorthodox or unusual payment or inducement that would not be authorised by the Company in the ordinary course of business;
o To refuse any bribe or unorthodox payment and to do so in a manner that is not open to misunderstanding or giving rise to false expectation, and to report any such offers;
o Not to make facilitation payments. These are payments used by businesses or individuals to secure or expedite the performance of a routine or necessary action to which the payer of the facilitation payment has a legal or other entitlement.
o To report any breaches of the policy, related principles or standards or of any associated legislation.
7.4 The Company recognises that there are a number of emerging overseas markets in which the legal system is internally contradictory, a different cultural acceptance of malpractice is in place, and where bribery and corruption may take place. Ensuring compliance with our policies may be more difficult, however we recognise the importance of the rule of law and the elimination of corruption and will rigorously enforce this policy notwithstanding such difficulties.
7.5 Specifically, the company will use the Corruption Perception Index as an active tool to ensure that the closest attention is paid to the countries presenting the highest risk. The baseline will be to treat all overseas markets, whether public or private sector, without prejudice, as high risk sectors and shall apply the full scope of our anti-fraud and anti-corruption procedures accordingly.
8. The Responsible Officer
8.1 The Managing Director is the “Responsible Officer” who is responsible for ensuring that the Company has control systems and measures in place to enable the prevention and detection of inaccuracies, fraud and corruption. An Anti-Fraud & Corruption Policy helps towards discharging part of this responsibility.
8.2 Accordingly, the Responsible Officer will:-
o Take overall responsibility for the maintenance and operation of this Policy;
o Promote awareness of the principles and practices it contains;
o Maintain records of financial malpractice, including concerns and allegations received, matters arising
from audits, investigations and evidence and the outcomes;
o Report as necessary to the Board.
1.1 Smith & Ouzman Ltd (“the Company”) recognises that the offer and acceptance of gifts and hospitality can be part of building normal business relationships.
1.2 In different geographical locations, this practice can vary significantly, often depending on local laws and specific customs. Some gifts and hospitality can create improper influence and conflicts of interest and in some instances they can be viewed as bribes that could damage the Company’s reputation or even break the law.
1.3 The expectation is that all staff, being employees and International Agents in all countries in which we operate (“staff”), will conduct themselves with integrity, impartiality and honesty at all times.
2.1 The purpose of this policy is to set out the responsibilities of staff in observing and upholding our position on the offer and acceptance of gifts and hospitality, and to avoid the potential for any perceived or real conflict of interest or allegation of bribery or corruption.
3.1 This policy applies to all staff of the Company.
3.2 This policy should be read in conjunction with the Company’s Anti-Fraud and Anti-Corruption Policy.
4.1 A “gift” is defined as any item, cash or goods, or any service which is offered for personal benefit at a cost, or no cost, that is less than its commercial value.
4.2 “Hospitality” is defined as any generous or material welcome or reception that is more than an incidental kind, such as beverage or light refreshment.
5.1 Staff are prohibited from offering, soliciting or accepting any gift or hospitality which could reasonably be deemed likely to influence any future business decision.
5.2 The Company seeks to protect staff from allegations of impropriety by ensuring that the offer or acceptance of all forms of gifts and hospitality is transparent, approved and, where appropriate, recorded.
5.3 In determining whether the offer or acceptance of a gift or hospitality is appropriate, consideration should be given to the recipient or provider, the value, and the reason for it.
5.4 Staff must declare offers and acceptances of gifts and hospitality in accordance with this Policy’s guidelines.
6. Recording of gifts and hospitality
6.1 HR will record all reported gifts and hospitality in the “Gift and Hospitality Register” which shall be reviewed annually by the Board of Directors.
6.2 It is the staff member’s responsibility as a matter of corporate discipline to inform HR by email or in writing of any offer or acceptance of gifts or hospitality, whether accepted or declined, that fall within this Policy’s guidelines.
7. Raising concerns and seeking guidance
7.1 Staff are encouraged and directed to raise concerns with their line manager or HR about any instance of malpractice at the earliest possible stage.
8. Policy Guidelines
8.1 The primary responsibility for deciding whether the offer or acceptance of a gift or hospitality is appropriate lies with the individual member of staff.
8.2 Staff must ensure that the offer or acceptance of a gift or hospitality does not create, or appear to create, a conflict of interest for those involved.
8.3 Staff should consider whether attendance at a social hospitality event, eg sporting and cultural events, is appropriate to the business and whether the interests of the company can be clearly demonstrated, eg networking opportunities.
8.4 The offer or acceptance of gifts and hospitality must be consistent with the policy and laws of the applicable third party organisation or country
To ensure, through effective controls and procedures, that the company’s assets, including confidential information, are protected from fraudulent attack, misuse, corruption or loss. Key actions will be:
- To adopt a system of risk analysis to ensure all recognised threats are evaluated.
- To introduce security measure (e.g. physical, logical, authentication, encryption) to prevent fraud, disclosure of confidential information, loss or corruption of data.
- To promote and maintain security awareness amongst all personnel.
- To ensure that personnel employed by the company are suitable for working in a security printing
- To ensure that the company’s activities meet current legal and regulatory requirements.
- The purpose of the Policy is to protect the organisation’s information assets from all threats, whether internal or external, deliberate or accidental.
- The Board of Directors have approved the Information Security Policy.
- It is the Policy of the organisation to ensure that:
– Information will be protected against unauthorised access;
– Confidentiality of information will be assured;
– Integrity of information will be maintained;
– Availability of information is ensured as required by the business processes;
– Regulatory and legislative requirements will be met;
– Business Continuity plans will be produced, maintained and tested;
– Information security training will be available to all staff;
– All breaches of information security, actual or suspected, will be reported to, and investigated by, the Director responsible for Security.
- Procedures exist to support the policy. These include virus control, passwords and business continuity.
- Business requirements for the availability of information and information systems will be met.
- The Director responsible for Security has direct responsibility for maintaining the Policy and providing advice and guidance on its implementation.
- All managers are directly responsible for implementing the Policy within their business areas, and for adherence by their staff.
- It is responsibility of each member of staff to adhere to the Policy.
Our Quality Management Policy is to design and supply products and services which consistently and fully meet our customers’ requirements.
The company is committed to comply with those requirements and continually improve the effectiveness of our quality management.
To achieve this Policy we operate a Quality Management System to the requirements of BS EN ISO 9001: 2008.
We have established clear quality objectives which include security arrangements, a robust IMS Review strategy to meet objectives and our Quality Policy continue to be suitable to the business and our customers’ requirements.
All employees are fully briefed on the Quality Management System, and participate in continual training to ensure competence and awareness.