UK Anti-bribery policy)

Bribery undermines laws and poses a serious threat to economic progress throughout the world and to the operation of free markets in general. The UK Bribery Act 2010 is intended to respond to these threats, by providing robust offences, enhanced sentencing powers for the courts and wide jurisdictional powers.

The principal offences under the Act are:

  • two general offences covering the offering, promising or giving of a bribe (active bribery) and the requesting, agreeing to receive or accepting of a bribe (passive bribery);
  • a discrete offence of bribing a foreign public official in order to obtain or retain business or an advantage in the conduct of business;
  • an offence which can be committed by commercial organisations which fail to prevent bribery committed on their behalf;

The Thomas Miller Group is committed to conducting business in an ethical and honest manner and to implementing adequate systems for the prevention of bribery and corruption. Thomas Miller Group has a zero tolerance for bribery and corruption activities.

To achieve this objective Thomas Miller and all its associated businesses will work to identify and eliminate any form of bribery through a risk assessment process and ongoing monitoring and review.

All employees are prohibited from soliciting, arranging or accepting bribes intended for the business and or employee’s benefit or that of the employee’s family, associates or acquaintances.

This Policy extends to all the Group's business dealings and transactions in all countries, whether on its own behalf or on behalf of any business managed or operated, wholly or in part, by any Group company.

This Policy is given force in a detailed anti-bribery programme which will be regularly revised to capture changes in law, reputation demands and changes in the business.

Through the ‘Whistle Blowing Policy’ employees are encouraged to report any suspicion of bribery, safe in the knowledge that they are able to raise concerns and report violations in confidence and without risk of reprisal.