Business Principles - Bribery
We define bribery to be the offering or requesting of a financial or other type of advantage with the:
- Intention of inducing or rewarding improper performance of a function or activity;
- Knowledge or belief that accepting such a reward would constitute the improper performance of such a function or activity.
Based on this, the following business principles set out our firm commitment to countering bribery, with these reflected in procedures implemented. The Management Board has agreed by resolution to commit to such principles, with this in turn setting the tone that bribery is never tolerated.
Our business principles are as follows:
- We will carry out our business fairly, honestly and openly;
- We will not make nor accept bribes, nor will we condone the offering or the acceptance of bribes on our behalf, so as to gain a business advantage;
- We will keep to these principles even when it becomes difficult;
- We will avoid doing business with others who do not accept our values and who may harm our reputation;
- We will set out our processes for avoiding direct or indirect bribery, with a risk-based approach taken to these.
- We shall analyse which specific areas pose the greatest risks from bribery, to design and implement the programme accordingly.
Gifts and Hospitality
- We prohibit the offer or receipt of gifts and hospitality whenever they could affect or be perceived to affect the outcome of business transactions and are not reasonable and bona fide.
- We shall implement the Bribery Programme in all business entities over which we have effective control;
- For our associates where we have significant business relationships, we shall use our influence to encourage a reciprocal programme and to undertake due diligence that assesses their ethics;
- We shall undertake due diligence before appointing agents, with this fully documented;
- All agreements with associates shall require Director approval;
- The relationship shall be documented in accordance with associate templates;
- Agents and other intermediaries shall be required to contractually comply with our Bribery Programme;
- We shall not channel improper payments through agents;
- Remuneration paid to agents and other intermediaries shall be appropriate and justifiable for services rendered;
- We shall monitor the conduct of our agents and other intermediaries and have the right of termination in the event that they pay bribes or act in a manner inconsistent with our Bribery Programme.
- We shall ensure that our business principles are reflected in practices regarding recruitment, promotion, training, performance evaluation, remuneration and recognition;
- We will make it clear that no employee will suffer demotion, penalty, or other adverse consequences for refusing to pay bribes even if such refusal results in Harvey Nichols losing business.
- Directors, Managers and relevant employees shall receive appropriate training on the Programme;
- We shall maintain employee awareness as to the bribery risks that Harvey Nichols faces.
- We shall ensure that charitable donations and sponsorships are not used as a subterfuge for bribery;
- We shall document all charitable contributions made, with this being reviewed for appropriateness on a timely basis.
Raising Concern and Guidance
- We will rely on employees to raise concerns about bribery as early as possible. To this end, we shall provide secure and accessible channels through which employees and others will feel able to raise concerns and report violations in confidence and without risk of reprisal.
- We will annually review and update our Programme and processes as needed.
- We shall maintain accurate books and records that properly and fairly document all financial transactions;
- All records and transactions will be fully and appropriately documented.