Anti Bribery Policy

Anti Bribery Policy


1. Overview

It is important to realise that having an Anti Bribery Policy demonstrates SK Medical Practice Ltd is committed to complying with anti bribery legislation.


 2. Purpose

The purpose of this policy is to establish controls to ensure compliance with all applicable anti bribery and corruption regulations, and to ensure that SK Medical Practice Ltd business is conducted in a socially responsible manner.


 3. Scope

 3.1 Who is covered by the policy

In this policy, “third party” means any individual or organisation you come into contact with during the course of your work for SK Medical Practice Ltd, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

This policy applies to all individuals working at all levels, including senior managers, directors, employees and trainees (whether permanent, fixed term or temporary), collectively referred to as “employees” in this policy.


This policy covers

  • Bribes
  • Gifts and hospitality
  • Facilitation payments
  • Political contribution
  • Charitable contributions


3.2 Facilitation payments and kickbacks

Facilitation payments are a form of bribery made for the purpose of expediting or facilitating the performance of a public official for a routine government action, and not to obtain or retain business or any improper business advantage. Facilitation payments tend to be demanded by low level officials to obtain a level of service which one would normally be entitled to.


4.  Policy

Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal or a breach of trust. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

 It is our policy to conduct all of our business in an honest and ethical manner. We take a zero tolerance approach to bribery and corruption.  We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.

We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate.  However, we will remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct both at home and abroad. We take our legal responsibilities very seriously and as such all employees are made aware of the consequences of breeching any legal requirements.


4.1 Employee Responsibilities

You must ensure that you read, understand and comply with this policy:

  • Speak to a Line Manager/ Practice Manager to raise any concerns


5. Policy Compliance

 5.1  Compliance Measurement

The management team will verify compliance to this policy through various methods, including but not limited to, periodic walk threw, business tool reports, internal and external audits, and feedback to the policy owner.

5.2 Exceptions


5.3  None Compliance

An employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment and or prosecution.


6.  Related Standards, Policies and Processes

Bribery Act 2010