Automated Packaging Systems Ltd believes that integrity is of paramount importance in the workplace; indeed, it is one of the Company core values. The Company expects all employees, and those who work closely with us, to behave with integrity at all times. This includes a zero tolerance policy on bribery and corruption of any kind.
 
This policy is in line with the Bribery Act 2010. The Act relates to both the public and the private sector and is relevant to giving or receiving anything that could be interpreted as a bribe.

The Act provides:

• a general offence of bribery, which is defined as giving someone a financial or other advantage to induce them to perform their functions or activities improperly, or to reward them for having already done so
• an offence of bribing a foreign public official in order to win business, keep business or gain a business advantage for the organisation
• an offence relating to failure by a business to prevent a person associated with it from committing the above offences on its behalf in order to win business, keep business or gain a business advantage for the organisation

We will be open and honest in all that we do; our business is ethically and morally strong and each of us is accountable for our actions or inaction, when appropriate.

This policy applies to Automated Packaging Systems employees and employees of all subsidiary companies (Staff, contract and temporary). Other individuals performing functions in relation to the company, such as sub contractors or suppliers are also expected to adhere to its terms.

The integrity policy also forms part of all our contracts with sub-contractors, suppliers, their agents and any third party. The Policy applies to all those working for or on behalf of Automated Packaging Systems. We only do business in accordance with our integrity policy, of which the commitment to preventing corruption forms a part.

We believe bribery is committed when an inducement or reward is offered, promised or provided, requested, agreed to or accepted in order to gain any commercial, contractual, regulatory or personal advantage for Automated Packaging Systems Ltd, subsidiary companies or another related party.

No bribes of any sort must be offered, promised, requested, agreed or paid to or accepted from customers, our supply chain, politicians, government advisors or representatives, private person or company. It is not permitted to establish accounts or internal budgets for the purpose of facilitating bribes or influencing transactions (slush funds).

Excessive generosity in making gifts or giving entertainment or hospitality to parties from whom business is sought can be seen as bribery. However, reasonable gifts or hospitality can be for the quite legitimate purpose of creating goodwill or saying “thank you” for business already given. This is a difficult area, in which to make precise rules. The exercise of common sense is important.

In cases of sensitivity, for example if Automated Packaging Systems were to bid for a contract, consideration should be given as to whether the giving or receiving of gifts or private entertainment to/from persons connected with the bid is appropriate. If Automated Packaging is about to award important business to the supply chain the staff involved must not accept gifts or other benefits from members of the supply chain who may be involved.

This policy applies to the offer of gifts or hospitality by both employees of Automated Packaging Systems Ltd to a third party company or by third party companies to an employee of Automated Packaging Systems.

All gifts and hospitality being offered or accepted to/by an individual should be approved by the Managing Director /HR Manager before offer or acceptance.

• Employees and employee’s families should refuse to accept gifts or hospitability which could influence or appear to influence decisions or create a conflict of interest with the company.
• The acceptance and /or offer of small gifts such as flowers, and /or casual hospitality such as business lunches and dinners, is acceptable within reasonable  bounds, as long as it is a normal appropriate expression of business courtesy.
• The primary responsibility for deciding whether gifts or hospitality should be accepted lies with the employee, although guidance is always available from the Managing Director/ HR Manager.
  Hospitality and gifts should not only be analysed as individual offers, but also analysed in the context of the annual value of gifts or hospitality received from or offered to each company individual.

We will communicate this policy to employees through our established internal communications channels

We will also communicate this policy to our suppliers, contractors and business partners.

The Automated Packaging Systems Global Code of Conduct:
http://www.autobag.co.uk/APS/Company-Info/Code-of-Conduct/Statement.aspx

Some guidance on the UK Bribery Act:
http://www.justice.gov.uk/guidance/docs/bribery-act-2010-guidance.pdf