Anti-bribery and corruption policy

What this policy is for

A bribe is anything of value offered, given or accepted to persuade somebody to do their job improperly, or to reward them for having done so. The Bribery Act 2010 makes it an offence to give a bribe, to take one, and, for a business, to fail to stop the people who act for it from bribing on its behalf. Flower & Glory is an independent business, and an independent business can be asked for a bribe as easily as a large one, and we want everybody who works with us to know where we stand before the question ever comes up.

We do not pay or accept bribes, and we do not use anybody else to do either for us.

Who it applies to

This policy applies to the owner, to every member of staff, permanent or seasonal, and to anybody acting on our behalf, including a courier, a freelance florist helping at a wedding, or a contractor working on the shop. We ask every supplier to accept our Supplier code of conduct, which carries the same rule.

What we will not do

• Offer, promise or give anything (money, goods, a free bouquet, a favour) to a person in a business, a council or a public body to win an order, a contract, a licence or a decision.
• Accept anything from a supplier, a customer or anybody else in return for buying from them, choosing them, or treating them better than we should.
• Pay a "facilitation" payment: a small sum to speed up something we are entitled to anyway, such as a delivery, a permit or an inspection. If one is demanded, staff should refuse, pay only if they believe their safety is at risk, and tell the owner the same day.
• Make political donations. Charitable giving, including our Poppy Appeal sales, is decided by the owner and recorded in the accounts.

Gifts and hospitality

Flowers are a gift trade, and we will not pretend that a bunch of tulips handed over at Christmas is a threat to anybody's judgement. The test is whether the thing given or received is open, modest, occasional and could not be mistaken for a reward for a decision.

• Staff may accept a small gift from a customer (a box of chocolates, a bottle of wine, a tip) and should tell the owner about anything worth more than roughly £50. Cash from a supplier is never accepted.
• Staff may give a bunch or a small discount as ordinary goodwill (a bouquet to a regular whose order went wrong, a discount to a neighbouring shop) and should record it as they would any other discount.
• Hospitality from a supplier (a trade lunch, a trip to the auction or a trade show) is accepted only with the owner's agreement, and never in the weeks before we decide whether to keep buying from them.
• Anything offered to a person at a school, a hospital, a council or another public body in connection with an order from that body goes through the owner, and is a gift to the body, not the person.

The owner keeps a simple gifts and hospitality log: what, from or to whom, when, and its rough value.

Records

Every payment in and out of the business goes through the till, the website or the accounts in Xero, and every expense claim carries a receipt. We do not keep cash off the books and we do not describe a payment as something it is not. An accurate record is the simplest protection there is against a bribe hiding in the accounts.

Raising a concern

If you are offered a bribe, asked for one, or think one has been paid, tell the owner as soon as you can. You will not be treated worse for refusing a bribe, even if the business loses an order because of it. If the concern is about the owner, our Whistleblowing policy gives an external route.

What happens if the policy is broken

Bribery is a criminal offence for the person and can be one for the business. A member of staff who pays or takes a bribe will face disciplinary action up to and including dismissal, and we may report the matter to the police. A supplier found to be paying or taking bribes in connection with our business will be dropped.

Questions and complaints

If you have a question about this policy, or a concern about bribery involving our business, write to enquiries@flowerandglory.co.uk, telephone 01732 743419, or write to Flower & Glory, 12 Blacks Yard, Blighs Meadow, Sevenoaks, Kent TN13 1DS.

Changes to this policy

Changes to this policy are dated and logged on the page where it is published, so you can see what changed and when.