As a mutual insurer we set great store by fairness between Members and probity when dealing on their behalf. In support of our commitment to maintaining the highest possible standards of business practice we hold a 'zero-tolerance' stance towards bribery. Bribery is illegal and as such has no place in our organisation. This policy also applies to all third parties who act on behalf of the UK Club.
The UK Bribery Act 2010 comes into force on the 1st July, 2011. The Bribery Act reforms the criminal law to provide a new, modern and comprehensive scheme of bribery offences that will enable courts and prosecutors to respond more effectively to bribery at home or abroad.
Although the Act is from the UK, its implications can affect all our people, wherever in the world they are based.
In the UK “bribery” is used to describe a dishonest payment in money or in kind and “corruption” is used to describe the type of relationship brought about by bribery.
The principal offences under the Act are:
- two general offences covering the offering, promising or giving of a bribe (active bribery) and the requesting, agreeing to receive or accepting of a bribe (passive bribery);
- a discrete offence of bribing a foreign public official in order to obtain or retain business or an advantage in the conduct of business;
- an offence which can be committed by commercial organisations which fail to prevent bribery committed on their behalf;
Our managers, Thomas Miller, are committed to our zero-tolerance regime in relation to any form of bribery and corruption. The Thomas Miller Group Anti-Bribery Policy for all its subsidiaries and managed businesses is set out below. Please take the time to read this policy carefully.
Thomas Miller Group Anti-Bribery Policy
The Bribery Act 2010 came into effect on 1 July, 2011 and has a worldwide impact upon the conduct of our businesses.
The Board of Thomas Miller Holdings Ltd is committed to zero-tolerance in relation to any form of Bribery and Corruption.
To achieve this objective Thomas Miller and all its associated businesses will work to identify and eliminate any form of bribery through a risk assessment process and ongoing monitoring and review.
All employees are prohibited from soliciting, arranging or accepting bribes intended for the business and or employee’s benefit or that of the employee’s family, associates or acquaintances.
This Policy extends to all the Group's business dealings and transactions in all countries, whether on its own behalf or on behalf of any business managed or operated, wholly or in part, by any Group company.
This Policy is given force in a detailed anti-bribery programme which will be regularly revised to capture changes in law, reputation demands and changes in the business.
Through the ‘Whistle Blowing Policy’ employees are encouraged to report any suspicion of bribery, safe in the knowledge that they are able to raise concerns and report violations in confidence and without risk of reprisal.
Preventing and reporting bribery
All management staff working on behalf of the UK Club have a responsibility to prevent, detect and report bribery. We provide appropriate guidance to our staff in fulfilling this duty.
We expect similar standards from all suppliers, service providers and other third parties who act on behalf of the UK Club.
Should you hold any suspicion of bribery or attempted bribery committed by or against an employee, agent or other party acting on behalf of the UK Club, it must be reported immediately to the Compliance Officer of the UK Club managers, Thomas Miller. The Compliance Officer is Paul Knight (Tel +44 20 7204 2308; Email: firstname.lastname@example.org)
Interpreting the policy
If there is any doubt as to whether an action might constitute bribery the matter should be referred to the Compliance Officer for a decision.