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Anti-Bribery & Corruption Policy

1.Background

Choosing a mortgage these days is never easy. Do you opt for a fixed rate mortgage? A variable rate mortgage? Or perhaps an offset mortgage? Perhaps you are looking to upgrade your existing home, or take on a development project. Should you be looking at a secured loan or perhaps a bridging loan?

1.1 Definition of Corruption

Bribery and corruption can cause significant social harm, and unfortunately, they can be features of corporate and public life. Corruption can be defined as the abuse of public or private office for personal gain. It is important to note that corruption occurs even when there has not actually, been a benefit but an expectation of one. Corruption can also occur when relatives or friends/associates of an official receive a benefit.

1.2 Definition of Bribery

Bribery is a form of corruption. It can be defined as giving, promising, offering, requesting, agreeing to receive or the acceptance of any gift, fee, or other reward, to or from any person (in government or business), as an incentive to do something that is dishonest, illegal, improper or a breach of trust. Bribery can occur both actively and passively. Active bribery is when a person may try to corrupt another by giving or attempting to make a bribe. Passive bribery is when a person may act corruptly by seeking, agreeing to accept, or by accepting a bribe.

Bribery also includes ‘facilitation payments’ - the practice of paying a small sum of money to a public official (or other person) as a way of ensuring that they perform their duty, either more promptly or at all. This could trigger an offence of bribing a foreign public official, where there is an intention to induce improper conduct, including where the acceptance of such payments is in itself improper.

1.3 Legal Framework

The UK Bribery Act 2010 replaces the existing UK laws on bribery and corruption. It creates four new offences:

The only defence to this offence is to show that an organisation had in place ‘adequate procedures to prevent such bribery. The first three offences apply to UK Nationals and UK Ordinary Residents. The fourth offence, a new ‘corporate’ offence is applicable where an organisation fails to prevent bribery by persons acting on their behalf. It applies to UK businesses doing business in the UK or anywhere else in the world, and overseas businesses doing business in the UK.

The new UK Act also makes it easier for UK agencies such as the Serious Fraud Office to prosecute bribery and corruption offences, with companies facing unlimited fines if they are convicted and individuals facing up to ten years in prison. Most countries have laws that prohibit corruption. In addition, an increasing number of countries are adopting laws to prohibit bribery even when it is committed outside their own borders. A breach of any of these laws is a serious offence and could result in more than one jurisdiction imposing fines and imprisonment. Even the appearance of a breach of anti-bribery or anti-corruption laws could do .

2.Border Mortgage Services Approach

The reputation of Border Mortgage Services for open, fair, honest and lawful business activity is one of our greatest assets. We are committed to maintaining the highest standards of ethics and we do not tolerate any form of bribery or corruption.

3.The Border Mortgage Services Anti-Bribery and Corruption Policy

This policy applies to the staff, executives, contractors AR’s and consultants in relation to all activities undertaken by, or on behalf of Border Mortgage Services. We will ensure all parties are informed of this policy and encourage them to maintain equivalent standards or adhere to the principles in this policy.

4.Policy

4.1 Prohibited Action

All persons covered by the Border Mortgage Services Anti-Bribery and Corruption policy are prohibited from offering or accepting a bribe or being party to corruption, including:

4.2 Reporting

Any Bribery and Corruption concerns, linked to Border Mortgage Services, can be reported through the CrimeStoppers Integrity Line which is a free phone number for Border Mortgage Services referrals. The line is open 24 hours a day, 365 days a year.– 0800 555 111

Once reported, concerns of bribery and corruption will be investigated independently of the area that is the subject of the concern. The investigation will be confidential and impartial. Appropriate action will then be taken.

All persons covered by the Border Mortgage Services Anti-Bribery and Corruption policy must report any attempts of bribery and/or corruption to the Border Mortgage Services Anti-Bribery and Corruption Reporting Officer Alex Hill ahill@stonebridgegroup.co.uk

Any breach of this Anti-Bribery and Corruption Policy is a serious disciplinary issue and will be investigated in full. We will cooperate with the relevant authorities, and instances of corruption and bribery may result in dismissal, a fine and/or imprisonment if a criminal prosecution is pursued. The Anti-Bribery and Corruption Reporting Officer Alex Hill, will maintain a record of all reports of bribery and corruption received and their conclusion. This information is made available quarterly to the Board of Directors.

5. Policy Guidance

5.1 Blackmail and Extortion

Border Mortgage Services does not give in to any blackmail or extortion demands. Where life or health is threatened, the Anti-Bribery and Corruption Reporting Officer must immediately refer the issue to Board level.

5.2 Gifts, Hospitality and Expenses

Each *Business Unit should prohibit the offer or receipt of gifts, entertainment or expenses where such arrangements could affect the outcome of business transactions and are not reasonable bona fide expenditures. Each Business Unit should implement appropriate Gifts and Hospitality, and Conflicts of Interest policies. Border Mortgage Services policies are as follows:

Gifts and Hospitality policy. This policy provides guidance on the considerations that must be taken into account before making or accepting an offer of a gift or hospitality. Also covered are: – Approval processes – The process for disclosing the giving and receiving of gifts and hospitality • Conflicts of Interest policy. This policy sets out Stonebridge Group’s policy for the identification and management of conflicts of interest.

5.3 Political Donations

Contributions must not be made to political parties, organisations or individuals engaged in politics, to support a political party, election candidate, political cause or as a way of influencing or gaining business advantage. Political contributions include any contribution, made in cash or in kind, to support a political cause. Contributions in kind can include gifts of property or services, advertising or promotional activities endorsing a political party, the purchase of tickets to fundraising events and contributions to research organisations with close associations with a political party. The release of employees without pay to undertake political campaigning or to stand for office could also be included in the definition.

5.4 Charitable contributions and sponsorships

Each Business Unit should ensure that charitable contributions and sponsorships are not being used for bribery; for example, in some countries public officials may set up charities to receive bribes. Each Business Unit should implement appropriate policies to cover charitable contributions and sponsorships. Any charitable contributions made by Border Mortgage Services are approved by the Managing Director beforehand.

5.5 Procurement

Border Mortgage Services aims to obtain overall best value for money from appropriate and professional relationships with suppliers of goods and services. All purchasing (including outsourcing) must meet genuine business needs and utilise company resources in the most cost-effective manner. The selection of suppliers must follow an appropriate process to ensure value for money, which is maximised when the correct balance is achieved between customer satisfaction, purchase cost control, risk management and acquisition cost.

5.6 Policy Application

The senior management of each Business Unit has a responsibility to ensure that this policy is fully mented and that systems and controls are working effectively. This includes activities that are outsourced from their Business Unit. Senior managers must:

Evaluate potential new risks whenever an existing procedure is being amended, a new product is being designed or new market or sales channel is under consideration.

Assess the adequacy of existing controls following the discovery of actual bribery and corruption and consider implementing additional controls to mitigate any risk identified.

Each business unit should ensure that their procedures are appropriate and consistent with all laws relevant to countering bribery and corruption in the jurisdictions in which they operate, particularly laws that are relevant to specific business practices. The principles of this Anti-Bribery and Corruption policy should be adhered to.

The relevant investigations team will investigate all suspicious activity that indicates bribery or corruption and, where appropriate, the concerns will be reported to the relevant law enforcement and/or regulatory authorities.

*Business Unit- meaning any trading style, or AR.

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