Bribery and Corruption

At ELE, we keep things clean and simple. Integrity and fairness are at the heart of how we work, and we expect the same from everyone who works with us. This policy spells out our approach to bribery and corruption, whether in the UK or overseas. No cutting corners. No dodgy deals. No exceptions.

Who This Policy Applies To

This policy covers everyone working with us: employees, contractors, consultants, officers, interns, casual staff, agency workers, and anyone else under our control.

If you’re an employee, this policy isn’t part of your employment contract, and we may update it when needed.

If you breach this policy, you could face disciplinary action, including dismissal for gross misconduct. You might also be committing a crime, which could lead to prosecution.

Our Commitment and Your Role

We’re committed to running ELE with integrity. Bribery and corruption have no place here.

If you work with us, you have a responsibility to help prevent and spot bribery or corruption in any part of our business.

If you see or suspect something that doesn’t seem right, speak up. Talk to your manager or a Company director. Our Whistleblowing Policy has more on how to report concerns safely.

We take every report seriously. If you refuse to be part of bribery or corruption or raise a concern in good faith, we’ll support you. If anyone treats you badly for doing the right thing, report it. If your manager doesn’t resolve it, follow our Grievance Policy.

And remember, you must never pressure or mistreat anyone who refuses to get involved in bribery or corruption or who reports a concern.

What Is Bribery?

Bribery is when someone offers, gives, asks for, or accepts something valuable to influence a decision unfairly. It could be money, gifts, hospitality, or favours — anything that gives someone an advantage.

You don’t need to actually hand over the bribe for it to count. Even offering or agreeing to it is enough.

Bribery is a serious crime. If caught, you could face up to 10 years in prison. ELE could also be fined and banned from public contracts if bribery happens under our watch.

Here are some examples of bribery. Don’t get involved in any of these:

  • Offering money or gifts to win a contract
  • Accepting gifts during tender processes
  • Taking cash or favours from someone hoping to land a business deal
  • Offering lavish hospitality in exchange for favourable treatment
  • Giving or accepting gifts to speed up routine processes
  • Giving gifts to government officials to influence decisions
  • Threatening or punishing someone who refuses to get involved in bribery
  • Retaliating against someone who reports concerns

What Is Corruption?

Corruption is abusing power or influence for personal gain. It can happen in many ways, but it always involves someone crossing the line for an unfair advantage.

What’s Allowed?

We’re not against genuine hospitality and building strong business relationships.

Here’s what’s OK:

    • Hosting or attending reasonable business hospitality
      Giving or receiving modest, thoughtful gifts with proper approval
    • Covering or accepting business-related expenses, like travel to a meeting

But there are rules:

    • Get your manager’s approval before giving or accepting gifts
    • Make sure the gift or hospitality is appropriate and not intended to influence a business decision
    • No cash or cash-equivalent gifts (like vouchers)
    • Gifts should be transparent and above board — no secrets
    • Always follow local laws
    • A branded mug or umbrella? Fine. A luxury weekend getaway? Not fine.

Kickbacks and Facilitation Payments

We don’t do kickbacks or facilitation payments. No exceptions.

  • Kickbacks are payments made to someone in return for a business favour.
  • Facilitation payments are small, unofficial payments to speed up routine processes. Think “back-handers.”

If someone asks you for a payment on ELE’s behalf, think carefully. Is it a legitimate expense?

Always get a receipt. If anything feels off, talk to your manager immediately.

Keeping Records

Transparency is key. You must keep clear records of:

  • Any gifts or hospitality given or received
  • All expenses, with full details of why the money was spent

Invoices and documents related to customers, suppliers, or any third parties must be complete and accurate. No hidden accounts. No shady bookkeeping.

At ELE, we believe in doing business the right way. That means keeping things fair, honest, and above board. Always.

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