Anti bribery and corruption policy

This policy is issued by Omni Management Ltd, trading as Omnium, registered in England and Wales, company number 14666993, registered office 18 Albert Road, Bournemouth BH1 1BZ.

It applies to every director, employee, contractor, agent and referral partner acting for us, in the United Kingdom and anywhere else we do business. It sits alongside the obligation in our client terms and conditions for clients to comply with the Bribery Act 2010.

We do not offer, promise, give, request, agree to receive or accept a bribe, whether directly or through a third party, and whether in the public or the private sector. We do not make facilitation payments. We do not permit anyone acting on our behalf to do so, and we will not accept a lower standard from a counterparty because a market or a jurisdiction is said to work that way.

The Bribery Act 2010 creates offences of offering or receiving a bribe, of bribing a foreign public official, and of a commercial organisation failing to prevent bribery by a person associated with it. The Act applies to conduct outside the United Kingdom as well as inside it.

Bribery is a criminal offence for the individual concerned and for the company. Penalties on conviction include imprisonment and unlimited fines.

• Giving or receiving any payment, gift, favour or other advantage intended to induce a decision, secure an appointment, or reward one that has been made.
• Payments to speed up a routine act by an official, however small and however they are described.
• Using a referral partner, introducer, consultant or supplier as a route for a payment that could not be made directly.
• Charitable or political donations offered, requested or accepted as an inducement.
• Retaliating against anyone who raises a concern in good faith under this policy.

Ordinary, proportionate business hospitality is allowed. It must be open, given in our own name, reasonable for the occasion, not offered around the time of a tender or contract decision, and it must never be cash or a cash equivalent.

Anything that is not clearly proportionate is declined or referred to a director before it is accepted or offered. Gifts and hospitality given or received in the course of our work are recorded in a register held by the company and reviewed by the directors.

Anyone appointed to introduce work to us, or to carry out work for a client on our recommendation, is engaged in writing, on stated fees, with this policy applying to the engagement. Payments are made only against a written agreement and an invoice that identifies the service provided. We do not pay undisclosed sums to a person who influences a client decision.

Our own remuneration is disclosed rather than concealed. Our third party intermediary disclosure sets out the basis on which suppliers and clients pay us, and clients can ask for the figures that apply to their own contract at any time.

If you are asked for a bribe, are offered one, or suspect that bribery has happened, report it as soon as you can. Email hello@askomnium.co.uk marked for the attention of the directors, telephone 01202 985126, or write to Omnium, 18 Albert Road, Bournemouth BH1 1BZ.

Concerns are investigated by a director who is not connected with the matter. A person who raises a concern in good faith will not be penalised, even if the concern turns out to be mistaken. Where the facts support it, we report the matter to the police or the relevant authority.

A breach by an employee is a disciplinary matter and may amount to gross misconduct. A breach by a contractor, agent or referral partner is grounds for ending the engagement with immediate effect. Where an offence may have been committed, we co-operate with the investigating authority.

The directors are responsible for this policy and for the controls behind it. It is reviewed at least once a year, and sooner if the law changes or an incident shows that a control needs to be stronger.