Policy Statement
At AB Whitney, it is our aim to operate all our business activities in the most responsible, honest and ethical manner. AB Whitney does not tolerate any form or act of 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 combat bribery and corruption.
Purpose
AB Whitney will continually adhere to all laws relevant to combating bribery and corruption in all the jurisdictions in which it conducts business. We are designed to adhere strictly to the Independent Corrupt Practices and Other Related Offences Act 2000 (the Act) and other related legislations in Nigeria, including the UK Bribery Act 2010 and the Foreign Corrupt Practices Act 1977 (FCPA) of America.
Scope and Applicability
This policy applies generally to all persons working for or on behalf of AB Whitney at all levels and grades, whether permanent, fixed-term or temporary, and wherever located, including consultants, contractors, seconded staff, casual staff, agency staff, volunteers, agents, sponsors and any other person who performs services for or on behalf of AB Whitney.
What is Bribery?
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 applicable anti-bribery and corruption laws, namely:
- giving or offering a bribe or property;
- receiving or requesting a bribe or property; or
- bribing a foreign public official,
- failure to report bribery transactions
Responsibilities and Raising Concerns
It is the responsibility of all personnel working for and on behalf of AB Whitney to prevent, detect and report bribery and other forms of corruption. They are all obliged to avoid any activity that might lead to, or suggest, a breach of this policy.
They are also required to notify AB Whitney as soon as possible where it is believed or suspected that a breach of this policy has occurred, or may occur, or if they are offered a bribe, are asked to make one, or suspect that this may happen in the future, or believe that they are a victim of another form of unlawful activity.
Anyone who breaches this policy may face disciplinary action, which could result in dismissal for gross misconduct. We reserve the right to terminate our contractual relationship with non-employee if they breach this policy.
If any Third Party is aware of any activity by any persons which might lead to, or suggest, a breach of this policy, they should raise their concerns with AB Whitney’s Anti-Bribery Compliance Officer.
In this policy, third party means any person or organization that comes into contact with AB Whitney’s business operations and includes actual and potential clients, intermediaries, referrers of work, business contacts, agents, advisers, government and public bodies (including their advisers, representatives and officials), politicians and political parties.
Training and Communication
Training on this policy is provided for any person working for or on behalf of AB Whitney and our zero-tolerance approach to bribery and corruption will, where appropriate, be communicated to clients, contractors and business partners.
Monitoring and Review
AB Whitney 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. The internal control systems and procedures are also monitored for effectiveness and subject to regular review to provide assurance that they are effective in combating any risks of bribery and corruption.
All our professionals or persons related to our business operations are aware that they are responsible for the success of this policy and should ensure they use it to disclose any suspected act or wrongdoing.
