Anti-Bribery & Corruption Policy

1. Policy Statement

MEL is committed to conducting recruitment, staffing and business activities honestly, transparently and responsibly. Bribery, corruption, improper payments, facilitation payments and other forms of unethical influence are not acceptable in any part of MEL's operations.

MEL expects employees, workers, contractors, candidates, suppliers, clients and other representatives acting on its behalf to maintain appropriate standards of integrity and to avoid situations where personal interests could improperly influence business decisions.

MEL will comply with applicable anti-bribery, fraud, corruption and financial crime legislation. This policy is intended to support compliance with applicable law and does not replace any statutory obligation or contractual requirement.

2. Purpose

The purpose of this policy is to:

• prevent bribery and corrupt practices;
• protect MEL, its candidates, workers, clients and business partners;
• establish clear standards for gifts, hospitality and business expenses;
• identify and manage conflicts of interest;
• provide a process for reporting suspected misconduct; and
• support a culture of ethical and transparent decision-making.

3. Scope

This policy applies to MEL employees, temporary workers, contractors, consultants and anyone acting on behalf of MEL.

It also establishes expectations for relationships with clients, candidates, suppliers, subcontractors, introducers and other third parties.

4. Definitions

Bribery means offering, promising, giving, requesting or accepting an advantage intended to improperly influence a person's actions or decisions.

Corruption means dishonest or improper conduct involving the misuse of entrusted power or position.

Facilitation payment means an unofficial payment intended to secure or speed up a routine action.

Conflict of interest means a situation where a person's personal, financial or other interests could improperly influence their professional responsibilities.

5. Prohibited Conduct

MEL prohibits:

• offering or accepting bribes;
• requesting improper payments from candidates or workers;
• making unofficial payments to public officials or other persons;
• creating false invoices or expense claims;
• concealing payments or benefits;
• using intermediaries to make payments that MEL could not lawfully make directly;
• accepting benefits that could improperly influence recruitment or placement decisions; and
• retaliating against a person who raises an anti-bribery concern in good faith.

6. Gifts and Hospitality

Reasonable and proportionate business hospitality may be acceptable where it has a legitimate business purpose and is not intended to influence a decision improperly.

Employees must not accept or provide gifts or hospitality where doing so could create an actual or perceived obligation, influence a recruitment decision, affect candidate selection, influence supplier selection or compromise professional judgement.

Cash or cash-equivalent gifts must not be accepted or offered in connection with MEL business.

7. Recruitment and Placement Controls

Recruitment decisions must be based on legitimate role requirements, candidate suitability, qualifications, experience, compliance requirements and client requirements.

No candidate should receive preferential treatment because of an improper payment, personal relationship or other undisclosed benefit.

Employees must not request money or personal benefits from candidates in exchange for interviews, placements, shifts or favourable treatment.

8. Conflicts of Interest

Any actual, potential or perceived conflict of interest must be disclosed promptly to the appropriate manager.

MEL will determine whether controls are required, which may include reassignment of responsibilities, additional oversight or withdrawal from a decision.

9. Third Parties

MEL will take reasonable steps to ensure that relevant suppliers, contractors and business partners understand the standards expected of them when working with MEL.

Higher-risk relationships may be subject to additional due diligence or contractual controls.

10. Reporting

Suspected bribery or corruption should be reported promptly to the appropriate manager or designated compliance contact.

Where the concern involves the person's manager, the concern should be escalated to another appropriate member of management.

11. Protection from Retaliation

MEL will not tolerate retaliation against a person who raises a genuine concern in good faith. Reports will be handled as confidentially as reasonably practicable.

12. Monitoring

MEL may review relevant financial records, expenses, supplier relationships, recruitment transactions and reported concerns to identify potential risks or irregularities.

13. Breaches

A breach of this policy may result in disciplinary action, termination of an assignment or contract, removal from an approved supplier or worker list, reporting to an appropriate authority, or other appropriate action.

14. Review

This policy will be reviewed at least annually and sooner where legislation, business activities, identified risks or regulatory expectations change.

15. Contact

MEL
6-9 The Square
Stockley Park
Uxbridge
UB11 1FW

Telephone: 020 8064 0994
Email: info@mymel.co.uk
Website: https://mymel.co.uk/

16. Approval

This policy is approved and maintained by MEL Management.