1. Purpose & Policy Statement
Rodan is committed to conducting its business with honesty, transparency and integrity. We adopt a zero-tolerance approach to bribery, corruption and improper payments whether in the private or public sector. This policy ensures compliance with the UK Bribery Act 2010 and protects Rodan, its employees and stakeholders from reputational or legal risk.
2. Scope & Applicability
This policy applies to all directors, officers, employees (including temporary and agency staff), contractors, consultants, subsidiaries and any persons acting on behalf of Rodan. It governs all dealings with customers, suppliers, partners and government officials both in the UK and internationally.
3. Definitions
Bribe: Offering, giving, receiving or soliciting an advantage to influence an action improperly.
Government Official: Any individual working in public office, for a public body or on behalf of a state-owned enterprise.
Gifts & Hospitality: Includes non-cash benefits such as meals, tickets, travel or entertainment.
Facilitation Payments: Small unofficial payments to expedite routine actions. These are prohibited under the Bribery Act 2010.
Conflict of Interest: A situation where personal interests interfere or appear to interfere with professional duties.
4. Prohibited Conduct
No person acting on behalf of Rodan may offer, promise or give a bribe to obtain or retain business.
No person may request, agree to receive or accept a bribe.
Facilitation payments are strictly forbidden.
Gifts or hospitality must never be excessive, inappropriate or intended to influence decision-making.
All gifts and hospitality must be transparently recorded and approved according to internal thresholds.
5. Gifts, Hospitality & Entertainment
Reasonable hospitality or token gifts may be acceptable if they are:
Modest, proportionate and infrequent
Not cash or cash equivalents
Disclosed and recorded in the Gifts & Hospitality Register
Thresholds:
Gifts exceeding £50 require written approval
Hospitality exceeding £200 requires prior authorisation
All gifts to public officials require pre-approval by the Compliance Officer
6. Third-Party Relationships
Rodan conducts due diligence on all third parties (agents, consultants, suppliers) to assess corruption risks. Contracts must include anti-corruption clauses granting audit and termination rights. Any suspected misconduct must be reported and reviewed immediately.
7. Reporting & Whistleblowing
All employees and associated persons must report suspected bribery, corruption or unethical conduct to the Compliance Officer. Rodan guarantees confidentiality and protection against retaliation for good-faith reports. Investigations will be handled promptly and discreetly.
8. Record Keeping
All financial transactions must be recorded accurately and in reasonable detail.
No off-book accounts or unrecorded funds are permitted.
False entries or concealment of payments are disciplinary and potentially criminal offences.
9. Training & Monitoring
Rodan provides regular training and guidance on anti-corruption and business ethics. Compliance audits will be carried out periodically. Senior management is responsible for promoting a culture of integrity and ensuring adherence to this policy.
10. Breaches & Sanctions
Breaches of this policy will be treated as gross misconduct and may result in disciplinary action including dismissal. Rodan and individuals may face prosecution under the Bribery Act 2010 which carries penalties of up to ten years' imprisonment and unlimited fines.
11. Roles & Responsibilities
Board of Directors: Overall responsibility for implementation and review.
Compliance Officer: Oversight, training and investigation of reports.
Managers: Ensure staff compliance and escalate concerns.
All Employees: Understand and comply with this policy and report concerns immediately.
12. Publication & Acknowledgement
This policy shall be published on Rodan’s official website and communicated to all relevant staff and partners. All employees must confirm in writing that they have read, understood and agreed to comply with the policy.
