Anti Bribary & Corruption
It is the policy of Domus Facades Ltd to conduct business in an honest and ethical manner. As part of
that, the Company takes a zero-tolerance approach to bribery and corruption and is committed to
acting professionally, fairly and with integrity in all its business dealings and relationships, wherever it
operates, and implementing and enforcing effective systems to counter bribery.
The Company will uphold all laws relevant to countering bribery and corruption in all the jurisdictions
in which it conducts business, including, in the UK, the Bribery Act 2010 (the Act), which applies to
conduct both in the UK and abroad.
Scope and applicability
This policy applies to all individuals working for or on behalf of the Company at all levels and grades,
whether permanent, fixed-term or temporary, and wherever located, including consultants,
contractors, seconded staff, casual staff, agency staff, volunteers, agents, sponsors and any other
person who performs services for or on behalf of the Firm, (collectively referred to as Workers in this
In this policy, Third Party means any individual or organisation that Workers come into contact with
during the course of work and the running of the Firm’s business, and includes actual and potential
clients, intermediaries, referrers of work, suppliers, distributors, business contacts, agents, advisers,
government and public bodies (including their advisers, representatives and officials), politicians and
What is bribery?
A bribe is an inducement or reward offered, promised or provided in order to improperly gain any
commercial, contractual, regulatory or personal advantage, which may constitute an offence under
the Act, namely:
giving or offering a bribe;
receiving or requesting a bribe; or
bribing a foreign public official.
The Company may also be liable under the Act if it fails to prevent bribery by an associated person
(including, but not limited to Workers) for the Firm’s benefit.
Gifts and hospitality
This policy does not prohibit normal and appropriate gifts and hospitality (given and received) to or
from Third Parties unless otherwise specifically stated. However, we have specific internal policies
and procedures which provide guidance to Workers as to what is to be regarded as normal and
appropriate gifts and hospitality in terms of financial limits, subject to the principles set out below
(the Overriding Principles), namely that any gift or hospitality:
must not be made with the intention of improperly influencing a Third Party or Worker to
obtain or retain business or a business advantage, or to reward the provision or retention of
business or a business advantage, or in explicit or implicit exchange for favours or benefits;
must comply with local law in all relevant countries;
must be given in the name of the organisation, not in an individual’s name;
must not include cash or a cash equivalent;
must be appropriate in the circumstances;
must be of an appropriate type and value and given at an appropriate time taking into
account the reason for the gift;
must be given openly, not secretly; and
in the case of gifts, they must not be offered to, or accepted from, government officials or
representatives, politicians or political parties, without the prior approval of either the Firm’s
Anti-Bribery Compliance Partner or the Compliance Officer for Legal Practice (COLP) or
Compliance Officer for Finance and Administration (COFA).
What is not acceptable?
It is not acceptable for any Worker (or someone on their behalf) to:
give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope
that they or the Firm will improperly be given a business advantage, or as a reward for a
business advantage already improperly given;
give, promise to give, or offer, a payment, gift or hospitality to a government official, agent
or representative to facilitate or expedite a routine procedure;
accept payment from a Third Party where it is known or suspected that it is offered or given
with the expectation that the Third Party will improperly obtain a business advantage;
accept a gift or hospitality from a Third Party where it is known or suspected that it is offered
or provided with an expectation that a business advantage will be improperly provided by
the Firm in return;
threaten or retaliate against another Worker who has refused to commit a bribery offence or
who has raised concerns under this policy; or
engage in any activity that might lead to a breach of this policy.
We keep appropriate financial records and have appropriate internal controls in place which evidence
the business reason for gifts, hospitality and payments made and received.
Responsibilities and raising concerns
The prevention, detection and reporting of bribery and other forms of corruption are the
responsibility of all those working for us or under our control. All Workers are required to avoid any
activity that might lead to, or suggest, a breach of this policy
Workers are required to notify the Company as soon as possible if it is believed or suspected that a
conflict with this policy has occurred, or may occur in the future, or if they are offered a bribe, are
asked to make one, suspect that this may happen in the future, or believe that they are a victim of
another form of unlawful activity.
Any employee who breaches this policy may face disciplinary action, which could result in dismissal
for gross misconduct. We reserve our right to terminate our contractual relationship with nonemployee Workers if they breach this policy.
If any Third Party is aware of any activity by any Worker which might lead to, or suggest, a breach of
this policy, they should raise their concerns with the Managing Director, Nicholas Shannon.
Monitoring and review
The Company monitors the effectiveness and reviews the implementation of this policy at
appropriate intervals, considering its suitability, adequacy and effectiveness. Any improvements
identified are made as soon as possible. Internal control systems and procedures are also subject to
regular review to provide assurance that they are effective in countering any risks of bribery and
All Workers are aware that they are responsible for the success of this policy and should ensure they
use it to disclose any suspected danger or wrongdoing.
Mr. Nicholas Shannon January 2021