The Norths Group Ltd
- Purpose
The Norths Group Ltd (“the Company”) is committed to conducting all business in an honest, transparent, and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships, wherever we operate.
This policy outlines our position on preventing bribery and corruption in all forms and provides guidance to employees, contractors, and business partners on recognising and dealing with bribery and corruption risks.
- Scope
This policy applies to:
- All employees (permanent, temporary, or contract) of The Norths Group Ltd;
- Directors, officers, and shareholders;
- Consultants, contractors, agency workers, and any other individuals associated with the Company; and
- Any third parties acting on behalf of or representing The Norths Group Ltd.
- Definition of Bribery and Corruption
- Bribery is the offering, giving, receiving, or soliciting of any item of value (such as money, gifts, favours, or services) as a means of influencing the actions of an individual holding a position of trust.
- Corruption is the abuse of entrusted power for private gain.
Examples include:
- Offering a client a gift to secure a recruitment contract;
- Accepting cash or a favour from a candidate to secure employment;
- Making facilitation payments to speed up routine processes.
- Our Policy
The Norths Group Ltd strictly prohibits:
- The offering, giving, solicitation, or acceptance of any bribe, whether cash or other inducement, to or from any person or company;
- The use of Company funds or resources for unlawful, unethical, or corrupt purposes;
- Any activity that could be perceived as influencing business decisions inappropriately.
All business dealings must be conducted honestly, transparently, and in full compliance with the UK Bribery Act 2010 and all other relevant anti-corruption laws.
- Gifts and Hospitality
We recognise that occasional and modest gifts or hospitality may be part of building legitimate business relationships. However:
- Gifts or hospitality must never be offered or accepted with the intent to influence a business decision;
- Any gift or hospitality exceeding £50 in value must be declared to a Director and recorded in the Gifts & Hospitality Register;
- Cash gifts or equivalents (e.g., vouchers) are strictly prohibited.
- Facilitation Payments
The Norths Group Ltd does not make or accept facilitation payments of any kind. Facilitation payments are small, unofficial payments made to secure or expedite routine actions (e.g., processing permits or approvals).
- Political and Charitable Contributions
- The Company does not make political donations.
- Charitable donations must be transparent, properly recorded, and approved by senior management. They must never be used as a means to gain an improper business advantage.
- Responsibilities
All employees and representatives must:
- Read, understand, and comply with this policy;
- Avoid any activity that could lead to, or suggest, a breach of this policy;
- Report any suspected bribery or corruption immediately (see below).
Management is responsible for ensuring that adequate procedures are in place to prevent bribery and for promoting a culture of integrity across the organisation.
- Reporting Concerns
Employees are encouraged to report any suspicion or evidence of bribery or corruption. Reports can be made confidentially to:
- A Director of The Norths Group Ltd; or
- Via the Company’s whistleblowing procedure (if applicable).
All concerns will be investigated promptly and fairly. No employee will suffer retaliation or detriment for reporting concerns in good faith.
- Breach of Policy
Any employee who breaches this policy may face disciplinary action, up to and including dismissal for gross misconduct.
The Company may also terminate relationships with any third party found to have breached this policy.
Violations may also result in criminal prosecution under the UK Bribery Act 2010.
- Record Keeping
The Company will maintain accurate records of:
- All gifts, hospitality, and charitable donations;
- All third-party agreements and due diligence checks.
All financial records must reflect legitimate business transactions only.
- Training and Communication
The Company will provide appropriate training to employees to ensure understanding and compliance with this policy.
This policy will be communicated to all new employees, suppliers, and business partners.
- Review of Policy
This policy will be reviewed annually or as required to ensure continued suitability and effectiveness.
The latest version will always be available on request or via the Company’s internal systems.
Dan Carter
Managing Director
The Norths Group Ltd
