Sustainable Business Practices

Employee Well-Being Policy
Ethics and Honesty Policy
Equal Employment Opportunity Policy
Health and Safety Policy
Environment Policy
Anti-Bribery and Anti-Corruption Policy
Diversity Policy
POLICIES

Anti-Bribery and Anti-Corruption Policy


Introduction and Purpose

Lavan has a well established reputation for conducting business in an ethical and honest way.

Individually, and as a firm, we value, promote and maintain the highest levels of integrity, ethical behaviour and accountability.

Lavan has a zero tolerance approach to bribery and corruption.  The firm is comitted to conduct all business in an honest and ethical manner.

Lavan is committed to:

Who is responsible for compliance with this Policy

This sustainable business practice applies to all:

Policy

What are Bribery and Corruption?

Bribery is the most common form of corruption and can be broadly defined as offering, promising, giving, accepting or soliciting an advantage as an inducement or reward for an action which is illegal or a breach of trust.

Although many people think of bribery as involving giving someone cash, it can take many other forms including non-cash gifts, lavish entertainment or hospitality or even simply doing someone a favour.

Bribery takes place if:

It is important to remember that in most cases it will be irrelevant whether the bribe was accepted or not.  Merely offering the bribe will usually be sufficient for an offence to be committed.

Bribery can be direct (eg a person gives a bribe to someone) or indirect (eg a person procures someone else to give a bribe to another person).

Key risk areas for Bribery and Corruption

Gifts, Entertainment and Hospitality

Gifts, entertainment and hospitality include the receipt or offer of gifts, meals or tokens of appreciation and gratitude, or invitations to events, functions, or other social gatherings, in connection with matters related to our business.  These activities are acceptable provided they:

Lavan partners and staff must not accept gifts or entertainment where to do so might influence, or be perceived to influence, objective business judgement.

This policy does not prohibit giving normal and appropriate hospitality to, or receiving it from, third parties.

What is not acceptable?

Circumstances which are never permissible include examples that involve:

Approval Process

The acceptance of gifts and/or hospitality/entertainment invitations must be pre approved by the Managing Partner or your Supervising Partner or Manager.

Any breach of this policy will be regarded as a serious matter by Lavan and will result in disciplinary action up to and including termination of employment or contract.