VIRPIO LTD t/a VIRPIO SECURITY (“the Company”) has a clear policy to uphold responsible and fair business practices. We are committed to promoting and maintaining the highest level of ethical standards in relation to all business activities. We support our employees to make decisions in line with our stated position, ensuring compliance with the Bribery Act, 2010.
Our corporate conduct is based on our commitment to acting professionally, fairly and with integrity. VIRPIO SECURITY does not tolerate any form of bribery and corruption.
Purpose
The purpose of this policy is to set out the responsibilities of Company functions and business units in observing and upholding our position on bribery and corruption in line with the Bribery Act, 2010.
Scope
This policy applies to all VIRPIO SECURITY employees (staff, contract and temporary). Where we have a minority interest, we will encourage the application of this policy amongst our business partners including contractors, suppliers, and joint venture partners. This policy should be implemented in conjunction with the guidance
on giving and accepting gifts and hospitality within the Company.
Policy Statement
Our Company Business Principles set out our commitment to operate responsibly wherever we work and to engage the social, environmental, and ethical impact of our activities in the markets in which we operate.
Our first principle, ‘integrity in corporate conduct’, states that VIRPIO SECURITY does not engage in bribery or any form of unethical inducement or payment including facilitation payments and ‘kickbacks.’ All employees are required to avoid any activities
that might lead to, or suggest, a conflict of interest with the business of the Company.
Employees must declare and keep a record of hospitality or gifts accepted or offered, which will be subject to managerial review. We do not make direct or indirect contributions to political parties.
We will uphold laws relevant to countering bribery and corruption in all the jurisdictions in which we operate, particularly laws that are directly relevant to specific business practices.
Sanction for breach
Any breach of this policy will constitute a disciplinary offence and dealt with in accordance with the Company’s disciplinary procedure.
The following Act of parliament underpin this policy:
UK Bribery Act 2010
Responsibilities
The Directors will establish appropriate responsibilities and procedures within their operations. If any instance of bribery or corruption is identified, we will take remedial steps immediately.
Training and communications
We will communicate this policy and relevant guidance to employees across the Company, through our established internal communication channels. We will also communicate this policy to our suppliers and contractors. Managers and employees
will receive relevant training on how to implement this policy in the scope of their employment with the Company.
Whistleblowing
Employees are encouraged to raise concerns about any instance of malpractice at the earliest possible stage in total confidence to their immediate manager/supervisor.
Monitoring and review
VIRPIO SECURITY will review the implementation of this policy in respect of its suitability, adequacy and effectiveness and make improvements as appropriate.
Internal controls and audit
The Company will establish feedback mechanisms in order to maintain accurate records – available for inspection – which properly and fairly document all financial transactions. Internal control systems will be subject to regular audits to provide
assurance that they are effective in countering bribery and corruption.
