Anti-Bribery and Corruption Policy 

Cole Waterhouse is committed to maintaining the highest levels of conduct and integrity, to ensure compliance with ethical and legal standards including those set out in the Bribery Act 2010. We value our reputation for conducting our business in a fair, honest and transparent manner. 

This Policy sets out the behaviours we expect of everyone engaged by us when conducting business on our behalf. We are fully committed to ensuring that no bribes or corrupt payments are made, offered, sought or received by anyone acting on our behalf. When working for us, you are agreeing and are obliged to uphold this commitment and always follow the requirements of this Policy. 

We expect all employees to demonstrate honesty, integrity and fairness in all aspects of their business dealings and exercise appropriate standards of professionalism and ethical conduct in all their activities. We expect the same approach to doing business from our business partners, agents and construction delivery partners and their supply chains. 

Our Policy 

We will take appropriate steps to ensure that: 

  • We do not, directly or indirectly, offer, promise, give, accept or demand a bribe or other undue advantage (including excessive gifts and hospitality) in order to obtain or retain business, or gain any other improper advantage. 
  • We know the third parties we are dealing with and only do business with them if they are reputable. 
  • We only engage and remunerate agents and other third parties for legitimate services and adopt appropriate transparency in our approach. 
  • We promote employee awareness, and have mechanisms in place for employees to report bribery or corruption. 
  • We raise awareness of the need to combat bribery and corruption with our business partners by publication of this Policy. 
  • We adopt financial accounting and auditing practices that prevent the creation of documents which do not properly and fairly record the transactions to which they relate. 


It is not the intention of the Bribery Act or this Policy to prohibit bona fide hospitality, promotional or other business expenditure to promote Cole Waterhouse and to establish or maintain cordial relations, which is an important and established part of how we do business. 

However, it should be reasonable and proportionate. Hospitality and gifts should only be accepted if they are: of reasonable value; appropriate; provided for the right reason; free from obligation; free from expectation; given openly; conform to the law and are infrequent. If you are in any doubt as to whether something is right, ask a member of the Board. 

Each of us has a responsibility to speak out if we discover anything corrupt or otherwise improper occurring in relation to our business. We cannot maintain our integrity unless we do this. If you discover or suspect bribery or corruption, again you must report this to a member of the Board. 

We will act firmly with any failure to comply with this Policy. Any failure to comply by employees may lead to disciplinary action, and this action may result in dismissal for gross misconduct. 

This Policy has been approved and authorised by the Board and will be reviewed every 12 months. 

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