Policy Statement

Hanover Green is committed to the prevention, detection and elimination of all forms of corrupt business practice. The principals of Hanover Green do not tolerate any form of bribery or corruption and will strive to ensure that Hanover Green fully meets its obligations under the Bribery Act 2010 and that it carries out its business fairly, honestly and openly.

Purpose

Hanover Green’s anti-bribery and corruption policy sets out the framework for the prevention, detection and elimination of all forms of corrupt practice in the conduct of its business, to the benefit of maintaining its good reputation and its client and business partner confidence.

Scope

The Policy applies to all Hanover Green principals and staff including those permanently employed by Hanover Green, temporary agency staff and consultants. Hanover Green also expects its business partners, especially those introducing business to Hanover Green, to promote and follow its policy or equivalent policies of their own. Hanover Green will not do business with third parties which fail to conduct business in a manner which is consistent with its anti-bribery and corruption policy.

Training & Guidance

The principals of Hanover Green are committed to allocating adequate resources to the provision of training to ensure that personnel understand their obligations under the Bribery Act, including the potential sanctions for non-compliance.

Breaches of Hanover Green’s anti-bribery and corruption policy will be dealt with under Hanover Green’s disciplinary procedures. In the event of criminal conduct Hanover Green will involve the police or other relevant enforcement agencies.

Corporate Hospitality, Promotional Expenditure & Gifts

All Hanover Green principals and staff are aware that they must:

• only offer or accept gifts and hospitality that are customary and reasonable in terms of value and frequency
• never offer or accept any gift or hospitality if it may improperly influence a business decision or impair independence or judgement or give the appearance of doing so.

Incident Reporting

Personnel are encouraged to report potential breaches of the Bribery Act or Hanover Green’s anti-bribery and corruption policy to any principal of the practice.

Monitoring & Supervision

Adherence to Hanover Green’s anti-bribery and corruption policy will be monitored regularly internally and any breaches will be reported to the principals.