1. Purpose
This policy outlines BlueZeon’s commitment to operating with integrity and in full compliance with relevant anti-bribery and corruption legislation. As a professional Managed Service Provider (MSP) based in Milton Keynes, BlueZeon is committed to conducting business ethically and lawfully and to the highest professional standards. The organisation values its reputation and is dedicated to maintaining the trust of its customers, partners, and stakeholders.
2. Scope
This policy applies to all individuals working for or on behalf of BlueZeon, including employees, directors, contractors, consultants, and agency staff. It covers all business activities, whether conducted in the United Kingdom or internationally, and applies to both public and private sector interactions.
3. Legal Framework
The primary legislation governing this policy is the UK Bribery Act 2010.
This Act establishes criminal offences for:
Offering, promising, or giving a bribe;
Requesting, agreeing to receive, or accepting a bribe;
Bribing a foreign public official;
Failing to prevent bribery by an associated person (corporate offence).
Penalties under the Act can include unlimited fines, imprisonment for individuals (up to 10 years), and reputational harm to the business.
4. Definition of Bribery
Bribery involves the offering, giving, receiving, or soliciting of any item of value with the intent to influence the actions of an individual in a position of power.
Common examples include:
Providing gifts or hospitality to win business;
Accepting incentives in return for favourable treatment;
Making unofficial payments to accelerate routine government actions (facilitation payments).
All forms of bribery and corruption are strictly prohibited.
5. Policy Statement
BlueZeon maintains a zero-tolerance approach to bribery and corruption.
No employee, contractor, or representative may:
Offer, give, solicit, or receive bribes of any kind;
Engage in corrupt practices for personal or commercial gain;
Permit others to act improperly on behalf of the business.
All decisions and actions must align with the highest ethical standards and relevant legal obligations.
6. Gifts and Hospitality
Reasonable and proportionate gifts or hospitality may be permitted where they support legitimate business interests and do not compromise objectivity or impartiality.
Such gestures must:
Be of modest value and appropriate to the business context;
Not be intended to gain an improper advantage;
Be declared and approved in accordance with internal procedures.
Cash gifts or anything perceived to create a conflict of interest are strictly forbidden.
7. Responsibilities
All staff and representatives of BlueZeon are required to:
Familiarise themselves with this policy and comply fully;
Report any suspicions or incidents of bribery or corruption;
Avoid situations where personal or professional integrity may be compromised.
Managers have an additional responsibility to foster a culture of ethical conduct and to support compliance efforts within their teams.
8. Reporting Concerns
Any concerns related to bribery or unethical conduct should be reported promptly to the Managing Director. Reports will be treated confidentially and without fear of retaliation. BlueZeon is committed to supporting individuals who raise genuine concerns in good faith.
9. Training and Communication
New employees are introduced to this policy during their induction process. Ongoing awareness and periodic reviews are provided to ensure continued compliance. Given BlueZeon’s size, training is tailored to the scale and risk profile of the business.
10. Review and Updates
This policy is reviewed annually by the Directors of BlueZeon or in response to significant changes in legislation or business operations. Updates are communicated to all relevant personnel.
