ABC Policy
This document (“the Policy”) sets out The Search Group Limited’s (“TSG”) policy on the prevention of bribery.
The Policy states TSG’s standards for the conduct of business with respect to bribery and corruption, its commitment to business integrity, fairness, and the highest ethical standards in all its dealings.
Accordingly, TSG is committed to, and will obey, all relevant anti-bribery and corruption statutes and laws wherever it operates. TSG will never knowingly or intentionally engage in, facilitate, or condone bribery in any form, and will have procedures and controls in place to ensure that it makes good on that promise.
TSG does not, and will not, take part in acts of corruption. TSG will not engage in active or passive bribery either directly or indirectly. It will not facilitate, condone or encourage bribery. TSG will not make facilitation payments.
TSG prohibits its employees, from engaging in acts of corruption. This includes acts of active and passive bribery, as well as the facilitation, condoning or encouraging bribery. TSG employees are likewise prohibited from making facilitation payments (as defined above).
TSG associated parties are prohibited from active or passive bribery in furtherance of TSG business, as well as making facilitation payments with respect to any business on TSG’s behalf. TSG will not do business with any associated party it knows is involved in bribery or corruption on behalf of any other party other than TSG.
TSG does not, and will not, take part in acts of corruption. TSG will not engage in active or passive bribery either directly or indirectly. It will not facilitate, condone or encourage bribery. TSG will not make facilitation payments.
TSG prohibits its employees, from engaging in acts of corruption. This includes acts of active and passive bribery, as well as the facilitation, condoning or encouraging bribery. TSG employees are likewise prohibited from making facilitation payments (as defined above).
TSG associated parties are prohibited from active or passive bribery in furtherance of TSG business, as well as making facilitation payments with respect to any business on TSG’s behalf. TSG will not do business with any associated party it knows is involved in bribery or corruption on behalf of any other party other than TSG.
TSG does not, and will not, take part in acts of corruption. TSG will not engage in active or passive bribery either directly or indirectly. It will not facilitate, condone or encourage bribery. TSG will not make facilitation payments.
TSG prohibits its employees, from engaging in acts of corruption. This includes acts of active and passive bribery, as well as the facilitation, condoning or encouraging bribery. TSG employees are likewise prohibited from making facilitation payments (as defined above).
TSG associated parties are prohibited from active or passive bribery in furtherance of TSG business, as well as making facilitation payments with respect to any business on TSG’s behalf. TSG will not do business with any associated party it knows is involved in bribery or corruption on behalf of any other party other than TSG.
TSG does not, and will not, take part in acts of corruption. TSG will not engage in active or passive bribery either directly or indirectly. It will not facilitate, condone or encourage bribery. TSG will not make facilitation payments.
TSG prohibits its employees, from engaging in acts of corruption. This includes acts of active and passive bribery, as well as the facilitation, condoning or encouraging bribery. TSG employees are likewise prohibited from making facilitation payments (as defined above).
TSG associated parties are prohibited from active or passive bribery in furtherance of TSG business, as well as making facilitation payments with respect to any business on TSG’s behalf. TSG will not do business with any associated party it knows is involved in bribery or corruption on behalf of any other party other than TSG.
TSG does not, and will not, take part in acts of corruption. TSG will not engage in active or passive bribery either directly or indirectly. It will not facilitate, condone or encourage bribery. TSG will not make facilitation payments.
TSG prohibits its employees, from engaging in acts of corruption. This includes acts of active and passive bribery, as well as the facilitation, condoning or encouraging bribery. TSG employees are likewise prohibited from making facilitation payments (as defined above).
TSG associated parties are prohibited from active or passive bribery in furtherance of TSG business, as well as making facilitation payments with respect to any business on TSG’s behalf. TSG will not do business with any associated party it knows is involved in bribery or corruption on behalf of any other party other than TSG.
TSG does not, and will not, take part in acts of corruption. TSG will not engage in active or passive bribery either directly or indirectly. It will not facilitate, condone or encourage bribery. TSG will not make facilitation payments.
TSG prohibits its employees, from engaging in acts of corruption. This includes acts of active and passive bribery, as well as the facilitation, condoning or encouraging bribery. TSG employees are likewise prohibited from making facilitation payments (as defined above).
TSG associated parties are prohibited from active or passive bribery in furtherance of TSG business, as well as making facilitation payments with respect to any business on TSG’s behalf. TSG will not do business with any associated party it knows is involved in bribery or corruption on behalf of any other party other than TSG.
TSG does not, and will not, take part in acts of corruption. TSG will not engage in active or passive bribery either directly or indirectly. It will not facilitate, condone or encourage bribery. TSG will not make facilitation payments.
TSG prohibits its employees, from engaging in acts of corruption. This includes acts of active and passive bribery, as well as the facilitation, condoning or encouraging bribery. TSG employees are likewise prohibited from making facilitation payments (as defined above).
TSG associated parties are prohibited from active or passive bribery in furtherance of TSG business, as well as making facilitation payments with respect to any business on TSG’s behalf. TSG will not do business with any associated party it knows is involved in bribery or corruption on behalf of any other party other than TSG.
TSG does not, and will not, take part in acts of corruption. TSG will not engage in active or passive bribery either directly or indirectly. It will not facilitate, condone or encourage bribery. TSG will not make facilitation payments.
TSG prohibits its employees, from engaging in acts of corruption. This includes acts of active and passive bribery, as well as the facilitation, condoning or encouraging bribery. TSG employees are likewise prohibited from making facilitation payments (as defined above).
TSG associated parties are prohibited from active or passive bribery in furtherance of TSG business, as well as making facilitation payments with respect to any business on TSG’s behalf. TSG will not do business with any associated party it knows is involved in bribery or corruption on behalf of any other party other than TSG.
Conflicts of interest need not in themselves be illegal, or indeed unethical. Quite often they are inadvertent. However, conflicts of interest considerably heighten the risk of unethical or illicit behaviour and can lead to such behaviour if not managed appropriately.
TSG will take all reasonable steps to avoid conflicts of interest in any dealings with clients or business stakeholders. Where TSG detects a conflict of interest involving a client or stakeholder it undertakes to inform the client or stakeholder, and to agree with them an appropriate course of action – including (if necessary) stepping away from a proposed project or, in a worst-case scenario, an entire business relationship.
Likewise, TSG’s employees and associated are expected as far as reasonably possible to avoid situations or transactions in which their personal interests could conflict (or might be seen to be in conflict) with those of TSG, its clients or other TSG stakeholders.
TSG’s employees and associated parties are required to report without delay any conflicts of interest between their own interests and TSG’s interests (which includes that of TSG’s clients and stakeholders), as soon as they become known, or as soon as the possibility might arise.
In this context personal interests can include those of parties closely associated with the employee, such as family members and friends.
A conflict of interest includes where an employee wishes to take a course of action which could potentially lead to an as yet unspecified conflict of interest, such as an investment. In such cases TSG requires the employee to seek guidance from TSG managers before the proposed action is taken.
Reports of conflict are to be made to senior managers within TSG. Separate procedures stipulate channels through which employees may escalate their concerns.
Conflicts of interest need not in themselves be illegal, or indeed unethical. Quite often they are inadvertent. However, conflicts of interest considerably heighten the risk of unethical or illicit behaviour and can lead to such behaviour if not managed appropriately.
TSG will take all reasonable steps to avoid conflicts of interest in any dealings with clients or business stakeholders. Where TSG detects a conflict of interest involving a client or stakeholder it undertakes to inform the client or stakeholder, and to agree with them an appropriate course of action – including (if necessary) stepping away from a proposed project or, in a worst-case scenario, an entire business relationship.
Likewise, TSG’s employees and associated are expected as far as reasonably possible to avoid situations or transactions in which their personal interests could conflict (or might be seen to be in conflict) with those of TSG, its clients or other TSG stakeholders.
TSG’s employees and associated parties are required to report without delay any conflicts of interest between their own interests and TSG’s interests (which includes that of TSG’s clients and stakeholders), as soon as they become known, or as soon as the possibility might arise.
In this context personal interests can include those of parties closely associated with the employee, such as family members and friends.
A conflict of interest includes where an employee wishes to take a course of action which could potentially lead to an as yet unspecified conflict of interest, such as an investment. In such cases TSG requires the employee to seek guidance from TSG managers before the proposed action is taken.
Reports of conflict are to be made to senior managers within TSG. Separate procedures stipulate channels through which employees may escalate their concerns.
TSG does not, and will not, take part in acts of corruption. TSG will not engage in active or passive bribery either directly or indirectly. It will not facilitate, condone or encourage bribery. TSG will not make facilitation payments.
TSG prohibits its employees, from engaging in acts of corruption. This includes acts of active and passive bribery, as well as the facilitation, condoning or encouraging bribery. TSG employees are likewise prohibited from making facilitation payments (as defined above).
TSG associated parties are prohibited from active or passive bribery in furtherance of TSG business, as well as making facilitation payments with respect to any business on TSG’s behalf. TSG will not do business with any associated party it knows is involved in bribery or corruption on behalf of any other party other than TSG.
TSG does not, and will not, take part in acts of corruption. TSG will not engage in active or passive bribery either directly or indirectly. It will not facilitate, condone or encourage bribery. TSG will not make facilitation payments.
TSG prohibits its employees, from engaging in acts of corruption. This includes acts of active and passive bribery, as well as the facilitation, condoning or encouraging bribery. TSG employees are likewise prohibited from making facilitation payments (as defined above).
TSG associated parties are prohibited from active or passive bribery in furtherance of TSG business, as well as making facilitation payments with respect to any business on TSG’s behalf. TSG will not do business with any associated party it knows is involved in bribery or corruption on behalf of any other party other than TSG.
TSG does not, and will not, take part in acts of corruption. TSG will not engage in active or passive bribery either directly or indirectly. It will not facilitate, condone or encourage bribery. TSG will not make facilitation payments.
TSG prohibits its employees, from engaging in acts of corruption. This includes acts of active and passive bribery, as well as the facilitation, condoning or encouraging bribery. TSG employees are likewise prohibited from making facilitation payments (as defined above).
TSG associated parties are prohibited from active or passive bribery in furtherance of TSG business, as well as making facilitation payments with respect to any business on TSG’s behalf. TSG will not do business with any associated party it knows is involved in bribery or corruption on behalf of any other party other than TSG.