WeKnow Media Ltd, the owners of IoT Now, is committed to carrying out its business and relationships professionally and with integrity and ensuring compliance with the requirements of the Bribery Act 2010. WeKnow Media is committed to the prevention, detection and deterrence of bribery. We take a zero-tolerance approach to acts of bribery and any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We may also look to prosecute those found to have been involved in acts of bribery. Any non-employee who breaches this policy may also have action taken against them.
Read our full policy below.
WeKnow Media’s commitment to the Policy
WeKnow Media is committed to carrying out its business and relationships
professionally and with integrity and ensuring compliance with the requirements of
the Bribery Act 2010.
WeKnow Media is committed to the prevention, detection and deterrence of bribery.
We take a zero-tolerance approach to acts of bribery and any employee who
breaches this policy will face disciplinary action, which could result in dismissal for
gross misconduct. We may also look to prosecute those found to have been involved
in acts of bribery. Any non-employee who breaches this policy may also have action
taken against them.
What are the aims and requirements of the legislation?
To ensure that WeKnow Media conducts its business to the highest legal and ethical
standards. WeKnow Media will not be party to corruption or bribery in any form. All of
us must work together to ensure that it is untainted by bribery or corruption. This
policy is a crucial element of that effort. Where Bribery is found to occur, in any form,
it will be dealt with rigorously in a controlled manner in accordance with the principles
in the Bribery Act policy. It will be investigated fully, and offenders will be prosecuted
where appropriate including, Members, employees, contractors and external
partners.
Who is governed by this Policy?
The Bribery Act policy covers everyone working for us, or on our behalf, in any
capacity including all permanent employees, temporary agency employees,
contractors, volunteers, interns, third-party representatives, consultants or any other
person associated with WeKnow Media.
Contents
The Bribery Act 2010 including the Aim and Scope of this policy
What are adequate procedures?
What are the principles?
Golden Rules
Employee Responsibilities
Reporting a concern
Further support and guidance
The Bribery Act 2010
Bribery is offering, promising, giving or accepting any financial or other advantage, to
induce the recipient or any other person to act improperly in the performance of their
functions, or to reward them for acting improperly, or where the recipient would act
improperly by accepting the advantage.
An advantage includes money, gifts, loans, fees, hospitality, services, discounts, the
award of a contract or any other advantage or benefit.
A person acts improperly where they act in breach of an expectation of good faith,
impartiality, or trust.
Bribery is a serious criminal offence with a maximum sentence of ten years’
imprisonment and/or an unlimited fine.
WeKnow Media can be held criminally responsible for failing to prevent bribery if a
person associated with the company bribes another person unless WeKnow Media
has in place adequate procedures to prevent this.
The aim of this policy
This policy provides a framework to allow those working for WeKnow Media, or on its
behalf, to understand and put into place arrangements to prevent bribery. It
demonstrates that WeKnow Media has implemented adequate procedures to
prevent bribery by persons associated with the company. It will work with related
policies, and other documents, to identify and report when this policy is breached
and aims to ensure that everyone:
- always acts with integrity and protects the WeKnow Media’s resources which they are responsible for; and
- keeps to the spirit, and letter, of the laws and regulations that cover our work
Scope of this policy
This policy applies to all our activities. All levels of WeKnow Media’s personnel are
responsible for controlling the risk of bribery. We encourage suppliers and other
organisations we work with to adopt policies that are consistent with the principles
set out in this policy.
The Anti-Bribery policy applies to and covers everyone working for us, or on our
behalf, all permanent employees, temporary agency, contractors, volunteers and
consultants. Everyone, at all levels of the council, has a responsibility to control the
risk of bribery occurring.
What are “adequate procedures”
For WeKnow Media to show that it takes the Bribery Act seriously, we need to show
we have adequate procedures in place designed to prevent bribery. Our procedures
need to be in proportion to the level of risk of bribery in our organisation. WeKnow
Media is committed to the six principles for bribery prevention issued by the Ministry
of Justice.
What are the principles?
- Proportionate procedures
WeKnow Media’s procedures to prevent bribery by a person associated with it are
proportionate to the bribery risks it faces and to the nature, scale and complexity of
the Council’s activities. The procedures are clear, practical, accessible and
effectively put into place and enforced. - Commitment at the top levels of our organisation
Our Senior Leadership Team are committed to preventing bribery by the people
associated with us. They help create a culture in our organisation where bribery is
never acceptable. - Risk assessment
We assess how and to what extent we will be exposed to potential risks of bribery as
part of a wider fraud risk assessment. We keep a record of the assessment, which
includes financial risks and also other risks such as damage to our reputation. - Due diligence
We apply due diligence procedures in relation to people who provide services for or
on behalf of our organisation to reduce the risks of bribery. - Communication
We aim to make sure that our policies and procedures to prevent bribery are
understood throughout our organisation. We do this through communication inside
and outside of our organisation. - Monitoring and review
We monitor and review the procedures designed to prevent bribery and make
improvements where they are needed. We are committed to putting these principles
into place as, should we be found guilty of an offence under section 7 of the Act, we
can be fined an unlimited amount. - Facilitation payments
Facilitation payments are unofficial payments made to WeKnow Media in order to get
the company to take certain actions or take actions more quickly. Facilitation
payments are illegal under the Bribery Act 2010 and we will not tolerate them. - Gifts and hospitality
Personnel associated with WeKnow Media should not accept anything with more
than a token value (examples of things that are of token value include bottles of
wine, boxes of chocolates, flowers, pens, calendars and diaries), with a minimal
value. Any Gifts and Hospitality offered that sits logically outside of these
parameters, should be reported to managers who can advise whether any further,
formal reporting, needs to happen. - Contracts and failure to prevent bribery
Persons and or companies are to be excluded from consideration of supplying or
working with WeKnow Media, if they have previously been convicted of a corruption
offence.
Golden Rules
We will not tolerate bribery and those covered by the policy must not:
- give, promise to give, or offer a payment, a gift or hospitality with the expectation or hope that they will receive a business advantage, or to reward a business advantage that they have already been given
- give, promise to give, or offer a payment, a gift or hospitality to speed up a routine procedure
- accept a payment from another person or organisation if they know or suspect that it is offered with the expectation that it will give them a business advantage
- accept a gift or hospitality from another person or organisation if they know or suspect that it is offered or provided with an expectation that they will provide a business advantage in return
- act against or threaten a person who has refused to commit a bribery offence or who has raised concerns under this policy; or
- take part in activities that break this policy
We are committed to:
- setting out a clear Anti-Bribery policy and keeping it up to date
- making all employees aware of their responsibility to always keep to this policy
- encouraging our employees to be aware and to report any suspicions of bribery
- providing our employees with information on suitable ways of telling us about their suspicions and making sure we treat sensitive information appropriately
- investigating alleged bribery and helping the police and other authorities in any prosecution that happens because of the alleged bribery
- taking firm action against any people involved in bribery
Employee Responsibilities
All the people who work for us or are under our control are responsible for
preventing, detecting and reporting bribery and other forms of corruption. All
employees must avoid activities that break this policy and must:
- make sure they read, understand and keep to this policy; and
- tell us as soon as possible if they believe or suspect that someone has broken this policy, or may break this policy in the future
Anyone covered by the policy found to break it will face disciplinary action, potentially
leading to dismissal for gross misconduct and/or may also face civil and/or criminal
prosecution.
Reporting a concern
We all have a responsibility to help detect, prevent and report instances of bribery. If
anyone has a concern about suspected bribery or corruption, they should speak up.
The sooner they act, the sooner the situation can be dealt with. There are several
ways of informing about any concerns including talking to a line manager first or one
going directly to the Managing Director.
Those reporting concerns do not have to give us their name. Upon receiving a report
about an incident of bribery, corruption or wrongdoing, action will be taken as soon
as possible to assess the situation. In some circumstances, we will have to consider
reporting the matter to the Police and/or other agency.
Employees that refuse to accept or offer a bribe, or those who report concerns or
wrongdoing can understandably be worried about what might happen as a result. To
encourage openness, anyone who reports a genuine concern will be supported
under this policy, even if they turn out to be mistaken. There is a commitment to
making sure nobody is treated badly because they have refused to take part in
bribery or corruption, or because they have reported a concern.
Further Support & Guidance
If there are any questions about this policy, please speak directly to your line
manager or approach the Managing Director, directly.
