Anti Bribery Policy

Anti Bribery Policy

Arrow Car Hire pledges to operate with integrity and honesty, enforcing measures to prevent bribery. We maintain a zero-tolerance stance towards bribery and corruption, ensuring all business dealings and relationships are conducted professionally, fairly, and with integrity.

Arrow Car Hire will adhere to all anti-bribery and corruption laws in every jurisdiction we operate. We comply with UK laws, including the Bribery Act 2010, both domestically and internationally.

We acknowledge that bribery and corruption can result in severe penalties, including imprisonment for up to ten years and substantial fines. Should Arrow Car Hire be implicated in corrupt practices, we may face unlimited fines, exclusion from public contract tenders, and significant reputational damage. Thus, we are committed to preventing bribery and corruption and take our legal obligations seriously.

SCOPE OF THIS POLICY

This anti-bribery policy applies to all personnel (temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or anyone associated with us (including third parties), or any of our subsidiaries or their employees, regardless of location (inside or outside the UK). The policy also covers Officers, Trustees, Board, and/or Committee members at any level.

In this policy, “third-party” refers to any individual or organisation Arrow Car Hire engages with. This includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and governmental and public bodies – including their advisors, representatives, officials, politicians, and public parties.

All agreements Arrow Car Hire makes with third parties are subject to clear contractual terms, including specific provisions requiring the third party to adhere to minimum standards and procedures concerning anti-bribery and corruption.

DEFINITION OF BRIBERY

Bribery involves offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or an advantage to influence an action or decision.

A bribe is any inducement, reward, or item of value offered to another person to gain a commercial, contractual, regulatory, or personal advantage.

Bribery is not just about offering a bribe. Accepting a bribe is also illegal.

Employees must not engage in bribery, whether directly, indirectly, or through third parties (such as agents or distributors). They must not bribe foreign public officials anywhere in the world. They must not accept bribes, and if they are uncertain whether something is a bribe or a gift, they should seek advice from the compliance manager.

ACCEPTABLE AND UNACCEPTABLE CONDUCT

This section covers four areas:

1. Gifts and Hospitality

Arrow Car Hire allows appropriate gestures of hospitality and goodwill (whether given to or received from third parties) as long as they meet the following criteria:

• It is not intended to influence the recipient to obtain or retain business or a business advantage, or in exchange for favours or benefits.
• It is not given with the expectation of a return favour.
• It complies with local laws.
• It is given in the company’s name, not an individual’s.
• It does not include cash or cash equivalents (e.g., vouchers or gift certificates).
• It is appropriate for the occasion (e.g., small gifts during holidays or as a thank you for project assistance).
• It is of suitable type and value, given at an appropriate time, and given/received openly, not secretly.
• It is not selectively given to influential persons intending to influence them.
• It does not exceed a value predetermined by the compliance manager (usually more than £100).
• It is not offered to or accepted from a government official or politician without prior approval from the compliance manager.

In situations where declining a gift would be inappropriate (e.g., when meeting someone of a certain culture/religion who might be offended), the gift may be accepted but must be declared to the compliance manager for assessment.

Arrow Car Hire acknowledges that the norms for giving and receiving business gifts vary across countries, regions, cultures, and religions. What is acceptable in one context may not be in another.

As best practice, all gifts given and received should be disclosed to the compliance manager. Gifts from suppliers must always be disclosed.

The intention behind a gift should always be considered. If there is any doubt, seek advice from the compliance manager.

2. Facilitation Payments and Kickbacks

Arrow Car Hire prohibits any form of facilitation payments. We understand that facilitation payments are bribes meant to expedite or facilitate routine government actions. Such payments are typically made by low-level officials to secure or speed up performance of duties.

Arrow Car Hire also prohibits kickbacks, typically exchanged for business favours or advantages.

We acknowledge that employees might encounter situations where avoiding a facilitation payment or kickback could risk their safety or that of their family. In such cases:

• Keep the payment to a minimum.
• Request a receipt stating the amount and reason for the payment.
• Record the payment details.
• Report the incident to your line manager.

3. Political Contributions

Arrow Car Hire will not make any donations, in cash or kind, to support political parties or candidates. We understand this could be seen as an attempt to gain an improper business advantage.

4. Charitable Contributions

Arrow Car Hire supports charitable donations—whether through services, knowledge, time, or direct financial contributions—and commits to disclosing all such donations.

Employees must ensure charitable contributions are not used to conceal acts of bribery.

We will ensure all charitable donations are legal and ethical under local laws and practices and that no donations are made without the compliance manager’s approval.

RESPONSIBILITIES

As an Arrow Car Hire employee, you must read, understand, and comply with this policy and any related training or anti-bribery information provided.

All employees and those under our control are equally responsible for preventing, detecting, and reporting bribery and other forms of corruption. They must avoid any activities that could lead to, or imply, a breach of this policy.

If you believe or suspect that bribery or corruption has occurred or may occur in the future, you must notify the compliance manager.

Employees breaching this policy will face disciplinary action, potentially including dismissal for gross misconduct. Arrow Car Hire reserves the right to terminate a contractor’s relationship if they breach this policy.

RAISING CONCERNS

This section addresses:

1. How to Raise a Concern

If you suspect bribery or corruption in connection with Arrow Car Hire, raise your concerns as early as possible. If unsure whether an action constitutes bribery or corruption, consult your line manager, the compliance manager, the director, or the Head of Governance and Legal.

Arrow Car Hire will familiarize all employees with whistleblowing procedures for raising concerns swiftly and confidentially.

2. What to Do if You Are a Victim of Bribery or Corruption

Inform your compliance manager immediately if you are offered a bribe, asked to make one, suspect you may be bribed or asked to make a bribe, or believe you are a victim of another corrupt activity.

3. Protection

Arrow Car Hire understands you might fear repercussions if you refuse to accept or offer a bribe or report a concern about bribery or corruption. We will support anyone who raises concerns in good faith under this policy, even if the investigation finds they were mistaken.

Arrow Car Hire will ensure no one suffers detrimental treatment for refusing to accept or offer a bribe or reporting a concern. Detrimental treatment includes dismissal, disciplinary action, threats, or unfavourable treatment related to the concern raised.

If you believe you have been unjustly treated due to a concern or refusal to accept a bribe, inform your line manager or the compliance manager immediately.

TRAINING AND COMMUNICATION

Arrow Car Hire will provide training on this policy as part of the induction for new employees. Employees will receive regular, relevant training on adhering to this policy and will be asked annually to confirm compliance.

Arrow Car Hire’s anti-bribery and corruption policy and zero-tolerance stance will be clearly communicated to all suppliers, contractors, business partners, and third parties at the outset of business relations and as appropriate thereafter.

Arrow Car Hire will provide relevant anti-bribery and corruption training to employees where their understanding of compliance with the Bribery Act needs enhancement. All businesses should offer anti-bribery training where there is a risk of encountering bribery or corruption in work activities.

RECORD KEEPING

Arrow Car Hire will maintain detailed and accurate financial records with appropriate internal controls to document all payments made. We will record the amount and reason for hospitality or gifts given and received, subject to managerial review.

MONITORING AND REVIEWING

Arrow Car Hire’s compliance manager is responsible for monitoring this policy’s effectiveness and will review its implementation regularly. They will assess its suitability, adequacy, and effectiveness.

Internal control systems and procedures to prevent bribery and corruption will be regularly audited to ensure they are effective in practice.

Any necessary improvements will be implemented as soon as possible. Employees are encouraged to offer feedback on this policy, addressing any suggestions for improvement to the compliance manager.

This policy does not form part of an employee’s employment contract and may be amended by Arrow Car Hire at any time to enhance its effectiveness in combating bribery and corruption.