In order to satisfy its obligations under the Bribery Act 2010 – Avoca expects all employees to demonstrate honesty, integrity and fairness in all aspects of their business dealings and to exercise appropriate standards of professionalism and ethical conduct in all their activities.

The Company expects the same approach from all of its business partners and suppliers. Pursuant to this, the Company will not tolerate bribery or corruption in any form and has a ‘zero tolerance’ approach to any breach of this policy.

This means that the Company and its employees will never seek, accept nor give a bribe, facilitation payment, kickback or any other improper payment. If you are in any doubt as to whether something is appropriate, ask yourself how your fellow employees would view your conduct, or how you would feel if your conduct featured on the front page of a national newspaper.

If you are in any doubt as to whether something is right, or if you are uncomfortable or concerned by the actions of others, you should ask your line manager.

Our Policy

We will take appropriate steps to ensure that:

• We do not, directly or indirectly, offer, promise, give, accept or demand a bribe or other undue advantage (including excessive gifts and hospitality) in order to obtain or retain business, or gain any other improper advantage.
• We do not offer, nor give in to demands, to make illicit or illegal payments to agents, public officials (at whatever level), or the employees of business partners or anybody else that we do business with.
• We engage and remunerate agents and other third parties only for legitimate services and adopt appropriate transparency in our approach.
• We promote employee awareness of, and compliance with, company policies against bribery and corruption through appropriate dissemination of our own procedures (including disciplinary procedures), policies and training programmes on induction and subsequently after any review or update.
• We adopt management control systems that discourage bribery and corruption and adopt financial and tax accounting and auditing practices that prevent the establishment of “off the books” secret accounts or the creation of documents which do not properly and fairly record the transactions to which they relate.
• We do not make illegal or inappropriate contributions to candidates for public office or to political parties or to other political organisations.
• We raise awareness of the need to combat bribery and corruption with our business partners by publication of this Policy and, where appropriate, relevant contractual provisions and support initiatives designed to reduce the risk of bribery and corruption.