The Bribery Act 2010 is arguably the toughest anti-bribery regime in the world. The Act imposes criminal liability on individuals and organizations in the event that employees, subsidiaries, agents or consultants pay or accept bribes in relation to the organization’s business anywhere in the world.
The Leadership Team and Council are fully committed to ensuring that GTEL operates as an ethical organization. Bribery or corruption in any form will not be tolerated. We expect our employees, stakeholders, members and business partners to conduct business in a fair, honest and ethical manner at all times.
The GTEL prohibits the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement to or from any person or company, wherever they are situated and whether they are a public official or body or private person or company by any individual employee, agent, member or other person or body acting on GTEL’s behalf in order to gain any commercial, contractual or regulatory advantage for GTEL in a way which is unethical or in order to gain any personal advantage, financial or otherwise, for the individual or anyone connected with the individual.
GTEL recognises that market practice varies across the territories in which we do business and what is normal and acceptable in one place may not be in another. This policy is not meant to prohibit the following practices providing they are customary in a particular market, are proportionate and are properly declared and recorded:
- Normal and appropriate hospitality
- The giving of a ceremonial gift on a festival or at another special time
- Use of any recognized fast-track process which is available to all on payment of a fee
- The offer of resources to assist a person or body to make a decision more efficiently, provided that they are supplied for that purpose only.
Inevitably, decisions as to what is acceptable may not always be easy. If at any time you are in doubt as to whether a potential act constitutes bribery, the matter should be referred to a responsible person within GTEL.
The prevention, detection and reporting of bribery is the responsibility of each individual working on behalf of GTEL. GTEL operates a zero-tolerance approach to any attempts at bribery by, or of, its employees and associated persons and encourages all such individuals to report any suspected bribery activity to a responsible person within GTEL. You will be fully supported if you make a report of suspected bribery in good faith even if, following an investigation, there is no finding that bribery took place.
In the event of any bribery activity being suspected, GTEL will carry out a full investigation and if any bribery activity is discovered, GTEL may:
- In relation to employees, invoke its disciplinary procedures, which could result in a finding of gross misconduct and immediate dismissal, or
- In relation to members, refer the matter to the Disciplinary Committee.
If you have any concerns or queries in relation to this statement or your obligations, please make these known to a responsible person within GTEL for advice.
Sincerely,
Jude Ebibokefie (PhD.)
Managing Director
Greenbelt Tropical Environs Limited