This page is provided for general company policy information. It should be read alongside Greystone Labour Ltd's Privacy Policy, Cookie Policy, Terms & Conditions and any worker/client agreements that apply.
1. Purpose
The purpose of this Anti-Bribery and Corruption Policy is to ensure that Greystone Labour Ltd conducts all business ethically, honestly, and with integrity. Greystone Labour Ltd has a zero-tolerance approach to bribery and corruption and is committed to complying with all applicable anti-bribery and anti-corruption laws and regulations.
2. Scope
This policy applies to:
All employees, regardless of employment status.
Directors and officers.
Temporary workers, contractors, consultants, and agency staff.
Volunteers and interns.
Suppliers, vendors, business partners, and other third parties acting on behalf of Greystone Labour Ltd.
3. Policy Statement
Greystone Labour Ltd prohibits all forms of bribery and corruption, whether direct or indirect.
No employee or representative shall:
Offer, promise, give, request, or accept a bribe.
Make or receive improper payments or inducements.
Use third parties to engage in bribery on Greystone Labour Ltd's behalf.
Attempt to influence business decisions through improper means.
Business decisions shall be based solely on legitimate commercial considerations.
4. Definitions
Bribery The offering, promising, giving, requesting, or accepting of an advantage or benefit intended to improperly influence a business decision or obtain an unfair advantage.
Corruption The abuse of entrusted power for private or Greystone Labour Ltdal gain.
Facilitation Payments Unofficial payments made to speed up routine government actions. These payments are prohibited unless there is an immediate threat to health or personal safety.
5. Gifts and Hospitality
Reasonable and proportionate gifts or hospitality may be accepted or offered where they:
Are lawful.
Are infrequent and of modest value.
Are transparent and appropriately approved.
Cannot reasonably be perceived as influencing a business decision.
Are accurately recorded where required.
The following are prohibited:
Cash or cash equivalents.
Lavish or excessive hospitality.
Gifts intended to secure an improper advantage.
Gifts during procurement or tender processes that could influence impartiality.
Employees should seek approval from management before offering or accepting gifts or hospitality above Greystone Labour Ltd's defined approval threshold.
6. Conflicts of Interest
Employees must:
Avoid situations where personal interests conflict with business interests.
Declare any actual, potential, or perceived conflicts of interest promptly.
Cooperate with any measures taken to manage identified conflicts.
7. Third Parties
Greystone Labour Ltd will:
Conduct appropriate due diligence on suppliers, contractors, agents, and business partners.
Include anti-bribery requirements in relevant contracts.
Monitor high-risk third-party relationships where appropriate.
Greystone Labour Ltd may terminate relationships with third parties that engage in bribery or corruption.
8. Charitable Donations and Sponsorship
Charitable donations and sponsorships shall:
Be made only for legitimate purposes.
Be properly approved.
Be accurately recorded.
Never be used to obtain an improper business advantage.
9. Political Contributions
Greystone Labour Ltd shall not make political donations or contributions unless expressly approved by the Board and permitted by applicable law.
Employees acting in a personal capacity must ensure that their political activities do not create a conflict of interest with their employment.
10. Record Keeping
Greystone Labour Ltd shall maintain accurate books and records that:
Reflect all transactions honestly.
Prevent hidden or off-the-books payments.
Support compliance with legal and financial reporting obligations.
False, misleading, or incomplete records are prohibited.
11. Reporting Concerns
Employees and third parties are encouraged to report suspected bribery, corruption, or unethical conduct immediately through Greystone Labour Ltd's reporting or whistleblowing procedures.
Reports will:
Be treated confidentially where possible.
Be investigated promptly and fairly.
Be handled without retaliation against individuals who report concerns in good faith.
12. Training and Awareness
Greystone Labour Ltd will provide:
Anti-bribery and corruption awareness training for relevant personnel.
Periodic refresher training.
Additional guidance for employees in higher-risk roles.
13. Responsibilities
Senior Management
Promote a culture of integrity.
Ensure appropriate resources are available for compliance.
Review the effectiveness of this policy.
Managers
Lead by example.
Ensure employees understand their responsibilities.
Escalate suspected breaches promptly.
Employees
Comply with this policy.
Complete required training.
Report suspected bribery or corruption.
Seek advice when uncertain.
14. Monitoring and Compliance
Greystone Labour Ltd will:
Periodically review anti-bribery controls.
Conduct internal audits where appropriate.
Investigate suspected violations.
Implement corrective actions as necessary.
15. Breaches of the Policy
Violations of this policy may result in:
Disciplinary action, up to and including dismissal.
Termination of contracts with suppliers or business partners.
Civil or criminal proceedings where applicable.
16. Policy Review
This policy shall be reviewed:
At least annually.
Following significant legal or regulatory changes.
Following any confirmed bribery or corruption incident.
As part of Greystone Labour Ltd's compliance programme.