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Achieving Growth

Anti-Bribery

Anti-Bribery and Corruption Policy
For Ranger4 Limited

January 1st 2024

Introduction
At Ranger4 we are committed to conducting business in a fair, honest, and transparent manner. We recognise that bribery and corruption present a risk to ethical business practices and have the potential to damage our reputation, relationships, and operations. As a small business operating in the UK, we uphold the highest standards of integrity in our dealings with clients, suppliers, contractors, and any other third parties we interact with.

This Anti-Bribery and Corruption Policy outlines our zero-tolerance stance towards any form of bribery or corrupt practices. The policy applies to all employees, directors, agents, consultants, contractors, and anyone acting on behalf of the company, regardless of their location or seniority.

Legal Framework
This policy is designed to comply with the UK Bribery Act 2010, which governs the prevention of bribery and corruption in the UK. The Bribery Act outlines four primary offenses:

  1. Offering, promising, or giving a bribe.

  2. Requesting, agreeing to receive, or accepting a bribe.

  3. Bribing a foreign public official.

  4. Failure by a commercial organisation to prevent bribery.

In line with this legislation, Ranger4 is committed to preventing bribery in all forms and requires all individuals associated with the company to abide by this policy and the relevant laws.

What is Bribery?
Bribery is the act of offering, promising, giving, or receiving something of value with the intention of influencing the recipient in the performance of their duties. A bribe can take many forms, including but not limited to:

  • Cash payments or gifts.

  • Entertainment, travel, or hospitality.

  • Favourable treatment in procurement processes.

  • Discounts or kickbacks.

  • Political or charitable donations intended to gain favour.

Bribery can involve the public or private sector and can occur directly or indirectly (e.g., through an agent or intermediary).

Our Stance on Bribery
Ranger4 has a zero-tolerance approach to bribery and corruption. We prohibit:

  • Offering, promising, or giving any form of bribe to secure business advantages or preferential treatment.

  • Soliciting, accepting, or receiving a bribe from any individual or organisation.

  • Engaging in corrupt practices when dealing with government officials, clients, suppliers, or other third parties.

  • Using third parties to carry out bribery or corrupt acts on our behalf.

This policy applies to all business dealings, regardless of location or local customs, and extends to interactions with public officials, private companies, individuals, or other entities.

Gifts and Hospitality
We understand that in some business contexts, giving or receiving gifts or hospitality can be a legitimate part of fostering good business relationships. However, any gift or hospitality that could be construed as a bribe or an attempt to influence business decisions is strictly prohibited. Employees must ensure that:

  • Any gift or hospitality given or received is reasonable, proportionate, and given in good faith.

  • Gifts or hospitality are not offered or accepted during any business negotiation or tendering process, as this could be perceived as a bribe.

  • The value of any gift or hospitality does not exceed £100, unless prior written approval has been obtained from senior management.

  • Records of all gifts and hospitality offered or received must be maintained and reported to the compliance officer.

Facilitation Payments
Facilitation payments, also known as "grease payments," are small, unofficial payments made to secure or expedite routine government actions, such as issuing permits or processing documents. These payments are illegal under the UK Bribery Act, and Ranger4 strictly prohibits making or accepting facilitation payments.

If an employee is requested or pressured to make such a payment, they must report the incident to senior management immediately. In cases where an employee’s safety is at risk, they may make the payment but must report the incident as soon as it is safe to do so.

Third-Party Relationships
We recognise that our business relationships with third parties, such as agents, consultants, contractors, and suppliers, can expose us to bribery risks. Therefore, we expect third parties acting on our behalf to uphold the same high standards of integrity. The following measures must be taken when dealing with third parties:

  • Conduct due diligence on all third parties before entering into any business relationship, particularly in high-risk regions or sectors.

  • Include anti-bribery clauses in contracts with third parties, ensuring that they understand and commit to abiding by our policy.

  • Monitor and review third-party relationships regularly to ensure ongoing compliance.

Political and Charitable Contributions
As a small business, Ranger4 does not engage in political donations or lobbying activities. Any charitable donations made on behalf of the company must be transparent, properly recorded, and not used as a cover for bribery or corruption.

Employees may not make personal political or charitable donations in exchange for business advantages or as a condition of doing business. Any charitable donations made on behalf of the company must be pre-approved by senior management.

Responsibilities of Employees
Every employee, regardless of their role or seniority, is responsible for upholding this policy and preventing bribery within their areas of influence. Employees are expected to:

  • Familiarise themselves with this policy and the UK Bribery Act.

  • Act with integrity in all business dealings.

  • Report any concerns or suspicions of bribery to the compliance officer or senior management.

  • Refuse to participate in any activity that could be construed as bribery or corruption, even if pressured by third parties.

Reporting and Whistleblowing
Ranger4 encourages all employees to report any suspicions or knowledge of bribery or corrupt practices within the company or its business relationships. Employees can raise concerns confidentially through our internal reporting channels. Any employee who reports suspected bribery in good faith will be protected from retaliation under our whistleblower policy.

All reports of bribery or corruption will be thoroughly investigated, and appropriate action will be taken. In the event that bribery is discovered, disciplinary measures, including termination of employment or contract, may be enforced. In some cases, legal action may also be taken.

Training and Awareness
To ensure the effectiveness of this policy, Ranger4 provides anti-bribery training to all employees, particularly those in high-risk roles such as procurement, sales, and finance. Regular refresher training is provided to keep employees updated on relevant laws, regulations, and company expectations.

Managers and senior leaders have a responsibility to ensure that their teams understand and adhere to this policy. Training records will be maintained to demonstrate compliance with this requirement. Risk assessments and internal audits are held each year.

Monitoring and Review
This Anti-Bribery and Corruption Policy will be reviewed annually, or sooner if required, to ensure its continued relevance and effectiveness. Changes to legislation, business operations, or risk factors may necessitate amendments to the policy. Any updates will be communicated to all employees, and additional training will be provided if necessary.

Consequences of Non-Compliance
Failure to comply with this policy could result in serious consequences for both the company and individuals involved. The penalties for bribery under the UK Bribery Act can include unlimited fines and imprisonment for individuals found guilty. Non-compliance may also result in significant reputational damage and the loss of business opportunities.

Conclusion
Ranger4 is committed to maintaining the highest ethical standards in all areas of our business. Bribery and corruption are not only illegal but fundamentally opposed to the values we stand for. Through this policy, we aim to ensure that our business remains fair, transparent, and accountable, and we expect all employees and third parties to share this commitment.

For any questions or concerns about this policy, please contact Steve Green (Steve.green@ranger4.com).

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