Introduction

Reddington Construction Ltd values its reputation and is committed to maintaining the highest standards of ethical conduct in all business dealings. The actions of our employees, as well as those acting on our behalf, play a vital role in upholding these standards. This policy sets out Reddington’s position on bribery and corruption and reflects our commitment to integrity, fairness, and transparency.

 

Scope

This policy applies to all employees, directors, officers, consultants, agents, contractors, and any other person or organisation acting for or on behalf of Reddington Construction Ltd, regardless of location or seniority. It applies across all business areas and activities.

 

Understanding Bribery and Corruption

We recognise that acts of bribery or corruption are intended to influence the actions of individuals in positions of trust and may incline them to act dishonestly. Bribery involves offering, giving, receiving, or soliciting a financial or other advantage with the aim of encouraging improper behaviour. Corruption is any abuse of entrusted power for private gain. It is important to understand that bribery is not limited to cash payments, it can include gifts, hospitality, favours, political donations, or any other form of inducement.

 

Policy Statement

Reddington Construction Ltd does not tolerate any form of bribery or corruption. We prohibit the offering, promising, giving, soliciting, or accepting of bribes, whether directly or indirectly. This prohibition applies whether the bribe is made to or by a public official, private individual, company, or any person or body acting on behalf of Reddington. The intention of the bribe, whether to gain business, secure a commercial advantage, or for personal benefit, is irrelevant. It will not be tolerated under any circumstances.

 

Hospitality, Gifts and Promotional Expenditure

We acknowledge that hospitality and promotional expenditure can play a legitimate role in building relationships. We do not prohibit normal and proportionate hospitality, provided it is reasonable, transparent, and recorded in accordance with our Corporate Entertainment Policy. Similarly, payments to fast-track services that are legally available to all on payment of a fee may be permitted, but only where they are lawful and properly authorised. Any uncertainty regarding whether a gift or payment is appropriate must be referred to a line manager or the Managing Director for guidance.

 

Legal Framework and Consequences

Reddington is aware of the potential consequences of breaching anti-bribery legislation. The Bribery Act 2010 provides for serious penalties – individuals found guilty of bribery may face up to ten years’ imprisonment and/or an unlimited fine. The company itself may also face unlimited fines if found to have failed to prevent bribery. Beyond the legal implications, involvement in bribery would cause significant reputational damage and undermine the trust placed in us by clients, partners, and the communities in which we work.

 

Bribery Risk Management

To mitigate bribery risk, we will carry out risk assessments across our operations and apply proportionate controls to prevent bribery occurring. We will undertake appropriate due diligence before engaging third parties, ensuring that we only do business with those who share our commitment to ethical practices. Contracts with consultants, suppliers and subcontractors will include clauses requiring compliance with this policy.

 

Staff Training and Awareness

All staff will receive training on anti-bribery and corruption as part of their induction, and further training will be provided as appropriate to ensure ongoing awareness. Employees must familiarise themselves with this policy and are encouraged to speak to their manager or the Managing Director if they are ever unsure whether something might constitute a bribe.

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High-Risk Areas

We recognise that some areas of our business carry a greater risk of exposure to bribery. These include hospitality, entertainment, facilitation payments, procurement decisions, and relationships with third parties. Our internal procedures and financial controls are designed to prevent bribery in these areas. Accurate record-keeping is essential to support transparency – any attempt to create false or misleading records will be treated as a serious breach of this policy.

 

Reporting Concerns and Responsibilities

The prevention, detection, and reporting of bribery is the responsibility of all staff. Anyone who becomes aware of, or suspects, a potential act of bribery must report it immediately to the Managing Director or a senior member of staff. All reports will be handled confidentially and investigated thoroughly. Retaliation against those who raise concerns in good faith will not be tolerated.

 

Monitoring and Review

Reddington Construction Ltd is committed to regularly reviewing the effectiveness of this policy and updating it as necessary in response to legal or operational changes. Senior management will lead by example, reinforcing the message that bribery and corruption have no place in our business.

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Breach of Policy

Any breach of this policy will be treated as a serious disciplinary matter and may lead to dismissal or termination of contract. In cases involving criminal conduct, the company will cooperate with law enforcement authorities.

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John Reddington

 

Managing Director

Reddington Construction Ltd

June 2025

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