1. Our commitment
Tuppence AI Ltd, which operates Tuppence, has zero tolerance of bribery and corruption. We will not offer, give, ask for or accept a bribe, in any form, anywhere we do business, and we will not let anyone do so on our behalf. We comply with the UK Bribery Act 2010 and, where they apply to us, the anti-bribery laws of the other countries we work in, including the US Foreign Corrupt Practices Act.
2. Who this applies to
This policy applies to our director, everyone who works for us (including contractors), and anyone who acts on our behalf, such as agents, resellers in our Partner Programme and advisers. We refer to all of them as “our people”.
3. What bribery is
A bribe is anything of value (money, a gift, hospitality, a favour, a job offer or a discount, for example) offered, promised, given, requested or accepted to make someone act improperly, or as a reward for having done so. It does not matter whether it is paid directly or through someone else, or whether the person involved works for a business or a government. Bribing a public official is a crime even when no improper act is intended, if the aim is to win or keep business.
Under the Bribery Act, a company also commits an offence if someone acting for it pays a bribe and the company had not put adequate procedures in place to prevent it. This policy is part of those procedures.
4. The rules
Our people must not:
- offer, promise or give a bribe, or ask for, agree to receive or accept one;
- make a facilitation payment: a small unofficial payment to speed up a routine government action, such as issuing a permit. They are illegal under UK law, and we do not make them anywhere. The only exception is a payment demanded under threat to someone’s safety or liberty, which must be reported to our director straight away;
- give anything of value to a public official, or to a card network, bank or regulator’s employee, to influence a decision about us;
- offer a business better terms, a lower rate or approval of its account in exchange for a personal benefit;
- make political donations on our behalf. We do not make them;
- make a charitable donation or sponsorship on our behalf that is linked to winning or keeping business;
- threaten or retaliate against anyone who refuses to pay or accept a bribe, or who raises a concern.
5. Gifts and hospitality
Modest, occasional gifts and hospitality, such as a working lunch or a branded notebook, are a normal part of business and are allowed if they are reasonable, given openly, not given in return for anything and not given while a decision involving the other party is pending.
- Any gift or hospitality with a value of more than £100 (or its equivalent in another currency), given or received, must be approved in advance by our director and recorded.
- Never give or accept cash or cash equivalents, such as gift cards or vouchers.
- Never give anything to a public official without our director’s prior written approval.
- Never accept a gift from a business while we are reviewing its account, its limits or a hold on it.
6. Partners and suppliers
We could be liable for bribes paid by people acting for us, so we:
- aim to check who we are dealing with before we appoint a reseller, agent or supplier, and do not knowingly work with anyone involved in bribery;
- make our Partner Programme terms and supplier contracts require compliance with anti-bribery law;
- pay commissions and revenue share only as our published terms set out, only to the business that earned them, and only into an account in its own name.
7. Records
We keep accurate books and records of every payment we make and receive, including expenses, commissions, gifts and hospitality. No payment may be disguised or recorded as something it is not, and no account may be kept off the books.
8. Raising a concern
If you are offered or asked for a bribe, or suspect bribery by anyone connected with Tuppence, tell us as soon as you can at contact@tuppence.ai. You can also raise it under our Whistleblowing Policy, which protects people who speak up in good faith. If you are unsure whether something is acceptable, ask before you act.
9. Breaches
Anyone who works for us and breaches this policy will face disciplinary action or the end of their engagement. A partner or supplier that breaches it may have its contract ended immediately. Where the law has been broken, we may report it to the relevant authorities.
10. Responsibility and review
Our director is responsible for this policy, asks everyone who works for us to read it when they join, and aims to review it at least once a year and whenever our business changes in a way that affects the risks.
11. About this policy
This is our internal policy, published for information. It does not form part of any contract with our customers, partners or suppliers (unless a contract expressly says so), and it does not give anyone outside Tuppence any rights, promise or warranty. We may change it at any time.