Vectura prohibits any inducement which results in a personal gain or advantage to the recipient or any person or body associated with them, and which is intended to influence them to take action which may not be solely in the interests of Vectura or of the person or body employing them or whom they represent.
Introduction
Prevention, detection and reporting of bribery are the responsibility of all employees. You must report any suspicion of bribery. In order to protect your identity you may choose to follow the whistleblower policy, a copy is available on the intranet.
Purpose
The purpose of this document is to serve as a guide for all employees of Vectura Limited and its affiliates (“Vectura”); it explains the steps needed to be followed in order to ensure Vectura maintains its values, adheres to corporate responsibility, society and legal expectations.
Policy
You must not, directly or indirectly,
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offer; give; solicit or accept any bribe, either in cash or any other form of inducement, to or from any person or company, wherever they are located and whether they are a public official or body or private person or company.
You must not, directly or indirectly,
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gain any commercial, contractual or regulatory advantage for Vectura in a way which is unethical.
Responsibility
This policy is applicable to all employees of Vectura, regardless of seniority.
You should not be prohibited from performing your work provided the activities are customary, appropriate and properly recorded, for example acceptable activities include:
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normal hospitality
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providing ceremonial gift on a festival or at another special time
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fast-tracking a process when it is available to all on payment of a fee
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providing resources to assist the person or body to make the decision more efficiently provided it is for this purpose only
Remember that market practice varies between countries and what is normal and acceptable in one place may not be in another, moreover our ethical values underpin any activity you undertake.
Adherence
It may not be easy to make a decision if something is appropriate. If you are in doubt that a potential act does not conform to this policy, the matter should be referred to the Chief Financial Officer.
Vectura will investigate seriously any actual or suspected breach of this policy, or the spirit of this policy. Employees may be subject to disciplinary action and which may ultimately result in their dismissal. In the case of third parties found to be bribing or attempting to bribe Vectura employees, a senior officer a supplier or customer they will be informed in writing business dealings will be ceased and appropriate authorities will be informed.