Introduction

SENSEI understands that bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision.    A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.   Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.   

SENSEI is committed to conducting business according to moral, ethical, and legal standards.  SENSEi does not allow and tolerate any kind of bribery and corruption.   This Anti-Bribery and Corruption Policy discourages and prohibits any kind of bribe or corrupt practice with any kind of stakeholder, including offering, promising, or providing any kind of means or value to any stakeholder, including client, government official, supplier to induce any improper action in relation to our business.   This Policy exists to set out SENSEI responsibilities and accountabilities in regard to observing and upholding our zero-tolerance position on bribery and corruption as well as act as a source of information and guidance. 

Objective 

This Policy outlines SENSEI’s moral and legal responsibility to counter bribery and corruption and provide tools and methods to keep check and balance on such practices  

Corruption  

For the purpose of this policy, bribery offences include bribes, kickbacks, extortions, either active or inducement of any kind. 

Gifts and hospitality  

SENSEI accepts normal and appropriate gestures of hospitality and goodwill (whether given to, or received from third parties) so long as the giving or receiving of gifts meets the following requirements:  

a. It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits.  

b. It is not made with the suggestion that a return favour is expected.  

c. It follows local law.  

d. It is given in the name of the company, not in an individual’s name. 

 e. It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).  

f. It is appropriate for the circumstances (e.g. giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).  

g. It is of an appropriate type and value and given at an appropriate time, considering the reason for the gift.  

h. It is given/received openly, not secretly. 

i. It is not selectively given to a key, influential person, clearly with the intention of directly influencing them. 

j. It is not above a certain excessive value, as pre-determined by the company’s compliance manager (usually in excess of £100).  

k. It is not offered to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s compliance manager. 

Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion / culture who may take offence), the gift may be accepted so long as it is declared to the compliance manager, who will assess the circumstances. SENSEI recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each. As good practice, gifts given and received should always be disclosed by the SENSEI employee to their Line Manager accordingly.  Gifts from suppliers should always be disclosed.  The intention behind a gift being given/received should always be considered.  

Penalty  

Violation of this Policy is highly discouraged.  If any SENSEI employee is found in violation of this Policy can face severe civil and criminal penalties in addition to disciplinary proceedings. 

Scope  

This policy applies to all SENSEI employees, directors, supply chain, clients and consultants.    Any arrangements SENSEI makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to anti-bribery and corruption.  

Applicable Laws 

This Policy is aligned to and governed by the UK Bribery Act 2010   

Prohibition of Bribery 

SENSEI employees are prohibited from offering, promising, or sanctioning any kind of payment to any company, organisation or government officials to secure improper business advantage.   SENSEI prohibits employees from taking any ill gain or advantage through improper means from any private or public entities. 

Policy Responsibilities 

SENSEi is ultimately responsible for ensuring that this policy conforms with legal and ethical commitments.   SENSEI is in charge of implementing this policy on a daily basis, monitoring its usage and effectiveness, managing lessons learnt, performance reporting, breaches, awareness, communication, reporting, and quality assuring internal control systems and processes ensuring their accuracy and relevance. 

SENSEI Management, at levels, is responsible for ensuring that direct reporting employees, consultants and suppliers understand and comply with this policy as well as undergo training on the policy and the subject of modern slavery in supply chains. 

SENSEi employees, sub-contractors, customers and suppliers who suspect misconduct, illegal activities, or violations of SENSEI’s policies are encouraged to report any concerns in accordance with SENSEi’s whistleblowing policy.