RSK GROUP PLC
RSK is committed to conducting its business according to ethical, professional and legal standards in an honest and transparent manner adopting a ‘proportionate procedures approach. The plc board will continue to develop the group’s anti-bribery and corruption procedures to ensure there is effective implementation of them, thereby aiming to establish a culture in which bribery and corruption are not acceptable.
The contents of SHEQ OP 20 (copy available on request), part of the group’s manual of operations have been noted by the board and endorsed as group policy as a code of conduct in so far as it refers to the Bribery Act 2010.
The board has drawn this statement to the attention of all UK employees and specifically the managing directors of all UK and foreign companies where RSK has an equity interest, whether a majority or minority holding. Those persons are aware of the penalties for non-compliance with this Act.
Any bribery and corruption exposes the group, its employees and ‘business partners’ to the risk of criminal prosecution and has a detrimental effect on its reputation. Any act that improperly influences the business outcome of tenders for work will not be tolerated. Any person suspected of improper behaviour should be reported to either his/her managing director or the RSK compliance officer. Upon receiving such an allegation, there will be an internal enquiry conducted and led by the group compliance officer and company secretary, Steven Mills. During this procedure, the individual (s) concerned may be suspended on full pay until the conclusion of enquiries.
On an annual basis, managing directors, in conjunction with their colleague directors and senior staff, will be required to conduct an assessment in their business so that procedures are in place to prevent and detect bribery and corruption. A summary report of assessments will be submitted to the plc board.
The group compliance officer is responsible for the implementation of appropriate business controls to reduce exposure to these risks and providing reports to the audit committee, which will monitor compliance on behalf of the plc board.
For the avoidance of doubt, RSK Group policy outlines the levels of corporate hospitality both received and offered that are considered commensurate with genuine business networking and improving customer relationships and procedures for authorisation.
Included within RSK Group’s standard terms and conditions of business is a statement about compliance with regulations set out in the Bribery Act 2010 so that suppliers, clients, consultants and agents (collectively business partners) can be aware of the board’s stance on this topic. Wherever reasonably possible, a requirement will be imposed on business partners to adopt similar practices and policies.
July 2014 (revised)