Bribery Policy
Business Principles - Bribery
Bribery, we define 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; and
• 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 being reflected in the procedures implemented. The Management Board has agreed by resolution to commit to adopt and commit to such Principles, which in turn sets the tone that Bribery is never tolerated.
Our Business Principles are as follows:
General
• We will carry out our business fairly, honestly and openly
• We will not make bribes, nor will we condone the offering of bribes on our behalf, so as to gain a business advantage
• We will not accept bribes, nor will we agree to them being accepted on our behalf in order to influence business
• 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, and keeping to and supporting our values
Risk Assessment
• 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, hospitality or expenses whenever they could affect or be perceived to affect the outcome of business transactions and are not reasonable and bona fide
Due Diligence
• We shall implement the Programme in all business entities over which we have effective control. For those where we have significant business relationships, to use our influence to encourage a reciprocal programme and to implement procedures that assess the ethics of the third party.
• We shall not channel improper payment through Agents
• We shall undertake properly documented due diligence before appointing Agents
• All agreements with associates shall require Director approval.
• Compensation paid to Agents and other intermediaries shall be appropriate and justifiable remuneration for legitimate services rendered
• Agents and other intermediaries shall contractually comply with our Bribery Programme.
• The relationship shall be documented in accordance with associate templates.
• 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.
Employment
• We shall ensure that practices regarding recruitment, promotion, training, performance evaluation, remuneration and recognition are reflected in our Programme
• 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.
Training
• 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
Charitable Donations
• 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 (“whistle-blowing”) in confidence and without risk of reprisal.
Monitoring Bribery
• We will annually review and update our Programme and processes as needed
Internal Controls
• We shall maintain for inspection accurate books and records that properly and fairly document all financial transactions.
• We shall not maintain off the books accounts