About This Policy
At Sutton House, we are committed to conducting our business honestly, ethically, and with integrity. We maintain a zero-tolerance approach to fraud, bribery, and corruption in all forms.
All business dealings and relationships are conducted professionally and fairly, in line with this policy. Breaches by employees may result in disciplinary action, including dismissal for gross misconduct. Non-employees breaching this policy risk immediate termination of contracts.
This policy is non-contractual and may be amended at any time, subject to regular review.
We undertake regular risk assessments to identify and mitigate risks, including reputational risks to our customers. Instances of fraud, bribery, or corruption within Sutton House or its supply chain may indicate broader illegal or unethical activity, such as modern slavery or human trafficking.
We foster an open and honest culture that encourages vigilance and integrity among personnel. Training and communication are provided to ensure all employees understand this policy and its processes, starting from induction.
Scope
This policy applies to all individuals working for or on behalf of Sutton House, including:
- Employees, directors, and officers
- Agency workers, seconded workers, volunteers, and interns
- Contractors, consultants, agents, third-party representatives, and business partners
What Is Fraud?
Fraud involves intentional deception for personal gain, to avoid obligations, or to cause loss. It includes, but is not limited to:
- Deception, bribery, forgery, extortion, theft, and embezzlement
- False representation, concealment of facts, and collusion
- Misuse of IT systems, theft of IT equipment or data, and dishonest manipulation of systems
What Is Bribery?
A bribe is a financial or other reward intended to induce improper behaviour or breach trust. Bribery includes:
- Offering, promising, or giving bribes
- Accepting or seeking bribes
- Bribes may take the form of money, gifts, loans, hospitality, services, contracts, or other benefits
Bribery is strictly prohibited. Specifically, you must not:
- Offer or give any payment, gift, or benefit in expectation of a business advantage or to reward business received.
- Accept offers from third parties expecting a business advantage in return.
- Make facilitation payments to government officials in any country.
- Retaliation against individuals who refuse to participate in or report bribery is strictly prohibited.
How to Raise a Concern
If you are:
- Offered a bribe
- Asked to make a bribe
- Suspecting fraud, bribery, or corruption
You must report this immediately to the Company Operations Director or raise it through our Whistleblowing Policy.
Investigation Process
Suspicions of fraud, bribery, or corruption will be investigated thoroughly, following recognised investigative techniques. Investigations will remain objective, confidential, and independent of the area where suspected wrongdoing has occurred.
Where appropriate, investigations will be referred to the police or relevant authorities. The rights of individuals involved will be respected throughout the process.
Employees involved in actual or attempted fraud will face disciplinary action, which may include dismissal. Sutton House will seek prosecution for any fraudulent activity and pursue recovery of assets through legal means.
All investigations will adhere to applicable legislation, including:
- Police and Criminal Evidence Act
- Data Protection Act
- Public Interest Disclosure Act
- European Convention on Human Rights
- Relevant local laws where applicable
- Lessons learned from investigations will be shared across the organisation to prevent future occurrences.
This policy reflects our unwavering commitment to ethical conduct and the prevention of fraud, bribery, and corruption within Sutton House and its business operations.