Anti-bribery & Corruption Policy
Policy Statement
Wellbeing Places REIG Limited ("we", "us", or "our") is committed to conducting all business with honesty, integrity and transparency.
We operate a zero-tolerance approach to bribery and corruption and expect the same high standards from all employees, contractors, consultants and business partners.
As a UK-based company, we comply with the UK Bribery Act 2010, which applies to our activities both in the United Kingdom and abroad.
Scope
This policy applies to all directors, employees and individuals working for or on behalf of WBP REIG, including contractors, consultants and other representatives. It covers all activities connected with the company's real estate investment and property management operations, including interactions with investors, tenants, suppliers, contractors, agents and public authorities.
All individuals within the scope of this policy are expected to act with integrity and comply with the UK Bribery Act 2010 in all business dealings.
What Are Bribery and Corruption?
Bribery is offering, promising, giving, or accepting any financial or other advantage, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage.
An advantage includes money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or anything else of value.
A person acts improperly where they act illegally, unethically, or contrary to an expectation of good faith or impartiality, or where they abuse a position of trust. The improper acts may be in relation to any business or professional activities, public functions, acts in the course of employment, or other activities by or on behalf of any organisation of any kind.
Corruption is the abuse of entrusted power or position for private gain.
Prohibited Conduct
No employee or representative of the company may:
- Offer or accept bribes, kickbacks or improper payments
- Provide gifts or hospitality intended to influence business decisions
- Accept personal benefits from contractors, suppliers or tenants
- Make unofficial payments to government officials or regulators
- Use third parties to engage in bribery on the company's behalf
Gifts and Hospitality
Offering, receiving, or soliciting gifts, hospitality, or other benefits that could improperly influence, or appear to influence, business decisions is not acceptable.
Our Gifts and Hospitality Policy provides further guidance.
Third-Party Relationships
WBP REIG recognises that bribery risks may arise through relationships with third parties acting on its behalf or providing services in connection with its business. The Company seeks to work only with reputable partners who share its commitment to ethical conduct.
Appropriate due diligence may be undertaken before entering into significant commercial relationships. Third parties are expected to comply with applicable laws, including the UK Bribery Act 2010, and to uphold standards consistent with this policy. Where appropriate, contractual arrangements may require adherence to these standards and allow the Company to take action in the event of misconduct.
Record-keeping
We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.
All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept "off-book" to facilitate or conceal improper payments.
Raising Concerns
WBP REIG encourages the prompt escalation of concerns relating to suspected bribery, corruption or any other breach of this policy.
Concerns may be raised through the Company's governance or whistleblowing arrangements and will be reviewed appropriately.
The Company does not tolerate retaliation against individuals who raise concerns in good faith.
Breaches of This Policy
Failure to comply with this policy may result in referral to the relevant authorities where required.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.