Anti-Bribery Policy

Your Excellent Health Service is committed to conducting its business around the world with the highest degree of integrity. This commitment includes a zero-tolerance approach towards all forms of bribery and corruption.

This policy has been formally approved by the YEHS management Team and extends to all individuals and organisations (e.g. health service professionals, and service providers) that the Group interacts with, as well as employees.

Definition of Bribery

The Bribery Act 2010 criminalises the act of offering, promising, or giving a bribe, as well as requesting, agreeing to receive, or accepting one. Additionally, it imposes liability on companies that fail to prevent bribery intended to secure or maintain business or an advantage in business dealings.

In alignment with our dedication to preventing and addressing bribery, YEHS will uphold robust procedures aimed at identifying and preventing such corrupt practices.

Policy Statement

YEHS expects honesty and integrity from its employees and all affiliated organisations in their business interactions, emphasising high standards of professionalism and ethical conduct. YEHS has a zero-tolerance policy towards bribery and corruption in any form and will strictly enforce this stance.

This policy aims to minimise the risk of bribery by:

Establishing and upholding a clear anti-bribery policy
Ensuring all employees and associated organisations understand their obligation to comply with this policy at all times
Thoroughly investigating any suspected bribery cases and cooperating fully with law enforcement and other relevant authorities in any ensuing prosecutions
Taking swift and decisive action against anyone found to be involved in bribery

Application

This policy prohibits all YEHS employees and associated organisations from:

Offering, accepting, or promising payments, gifts, or hospitality with the expectation of receiving or rewarding a business advantage
Accepting payments from third parties when there is knowledge or suspicion that the payment is intended to secure a business advantage for them
Retaliating against or threatening individuals who raise concerns under this policyGiving or accepting bribes from government or public officials
Participating in any actions that violate this policy

Responsibility

The prevention, detection and reporting of bribery and other forms of corruption is the responsibility of all employees and organisations that interact with YEHS, who are therefore required to read, understand and comply with this policy.

<p”>Individuals are expected to raise concerns as soon as possible, if it is believed or suspected that a conflict with this policy has occurred.

Reporting

YEHS provides multiple channels for reporting concerns. Employees should initially report suspicions to their Line Manager or, if that is not feasible, to the Head of Finance or CMD. Staff should also adhere to the procedure outlined in the company’s “Employment Policy.” All reports will be handled confidentially. Thorough and prompt investigations will be conducted for all actual or suspected bribery cases discovered or reported.

Employees who refuse to engage in bribery or report misconduct sometimes fear retaliation. We strive to promote transparency and will support anyone who raises genuine concerns in good faith under this policy, even if they are ultimately mistaken. However, if concerns are raised maliciously, employees will face disciplinary action according to YEHS Disciplinary procedure.

Data Protection

When someone makes a disclosure, the organisation will handle any personal data collected in line with its data protection policy.

From the moment the report is made, the data will be securely stored and only accessed or disclosed to individuals involved in addressing the disclosure.

Gifts and Hospitality

This policy allows for normal and appropriate hospitality (both given and received) with third parties, as long as the following criteria are met and the gifts or hospitality fall within the specified categories:

The gift or hospitality must not be intended to influence a third party to secure or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, nor should it be exchanged for favours or benefits.
It must comply with local laws.
It should be given in the name of the Company, not in your personal name.
Cash or cash equivalents (such as gift certificates or vouchers) are not allowed.
The gift or hospitality should be appropriate for the occasion (e.g., small
Christmas gifts are customary in the UK.
It should be of a suitable type and value for the occasion.
It must be given openly, not secretly.
Gifts should not be offered to, or accepted from, government officials, representatives, politicians, or political parties without prior approval from the Head of Finance.

The following are permissible, provided they comply with the above conditions:

Gifts valued at £50 (or equivalent) or less may be accepted with notification to the CMD & Head of Finance. If offered a gift worth more than £50 (or equivalent), it should generally be declined. However, if rejecting the gift could harm a business relationship, it should be discussed with the Head of Finance and may be accepted on the condition that it is donated to charity.

Normal business courtesies such as lunch, dinner, and invitations to concerts, theatre, and sporting events may be accepted if:

You confirm with a director or the Head of Finance that the invitation is in line with appropriate business practices.
The host is present.
Travel and accommodation costs are not covered by the inviting party unless approved by a director or the Head of Finance.
Offering similar business courtesies, such as lunch, dinner, and invitations to events, is allowed if the costs are approved in accordance with the YEHS expenses policy.
Gift-giving practices can vary by country and region, and what is acceptable in one area may not be in another. The key is to ensure that the gift or hospitality is reasonable and justifiable in the circumstances. Always consider the intention behind the gift.

Donations and Sponsorships

We limit our charitable contributions to UK-registered charities that align with YEHS’s values and objectives, and that are free from political motivations. Sponsorships are only provided if they are lawful and ethical according to local regulations and customs. All donations or sponsorship offers must receive prior approval from either a director or the Head of Finance.

Record-keeping

It’s imperative to maintain comprehensive financial and other records, along with implementing suitable internal controls, to document the business rationale behind payments to third parties.

You’re required to disclose and maintain a written record of all accepted or offered hospitality or gifts. The Administrative and Finance Team will manage a central log for this purpose.

Furthermore, you must ensure that any expense claims associated with hospitality, gifts, or expenses for third parties are submitted following our expenses policy, and explicitly state the purpose of the expenditure.

Who is Responsible for the Policy?

The Management Team holds the ultimate responsibility for ensuring that this policy aligns with our legal and ethical obligations and that everyone under our authority adheres to it. The Head of Finance bears primary responsibility for implementing and overseeing this policy on a daily basis, monitoring its application and effectiveness, and addressing any inquiries regarding its interpretation. Management at every level is accountable for ensuring that those under their supervision are informed about and comprehend this policy.

Monitoring and Review

The Head of Finance will oversee the efficacy and assess the execution of this policy, consistently evaluating its appropriateness, sufficiency, and efficacy. The Management Team will be accountable for any revisions to the policy. Internal control systems and procedures will undergo regular audits to ensure they effectively combat bribery and corruption.