POLICY STATEMENT  

This document outlines the policy of Digital Bricks Learning regarding the exchange of gifts, hospitality, and entertainment. It aims to ensure transparency, establish clear guidelines for appropriate conduct, and adhere to the requirements of the UK Bribery Act 2010. 

Bribery  
Bribery involves the act of offering, promising, giving, requesting, or accepting any financial or other benefit, or any form of inducement, from any individual or company (regardless of their location or whether they are a public official or entity, or a private individual or company). This can be conducted by an employee, associate, or any other person or entity representing another party. 

Corruption 
Corruption refers to the misuse of given authority for personal benefit. 

Our Ethical Stance 
Digital Bricks Learning firmly upholds the belief that the exchange of gifts does not align with the ethics of our business. We are committed to avoiding any form of bribery or illicit payments under all circumstances. Additionally, we strictly prohibit engaging in any corrupt practices, either directly or indirectly, such as to gain new business, renew existing contracts, or increase our financial returns. We also ensure that our associates who represent us adhere to these standards. 

In all dealings with clients and customers, especially concerning contract renewals, initiation of new projects, or adjusting pricing terms, we maintain absolute clarity and transparency. The same principle applies to our interactions with suppliers regarding pricing and terms of our agreements. We are dedicated to ensuring that all agreements related to our supply chain and client services are comprehensively documented. Any changes to our contracts, rebates, or work proposals will be made with proper consideration, ensuring they are justifiable, accurate, and fair. 

Under no circumstance will we engage in corrupt activities, and any significant actions or decisions will always be taken in consultation with our Board of Directors. 

Embracing our responsibilities 
At Digital Bricks, every employee and associate is held accountable for their actions and is expected to uphold a standard of integrity in their professional conduct. When faced with uncertainty about what constitutes appropriate behaviour or a specific course of action, it is advised to seek direction from the Director. It is imperative for every member of Digital Bricks Learning to be well-acquainted with and adhere to the relevant policies, laws, and regulations that govern our roles. We are committed to conducting our business in line with the highest ethical and legal norms.  Should there be concerns about Digital Bricks or our colleagues not meeting these standards, we encourage voicing these concerns. 

This policy serves as a set of guiding principles and may not cover every possible scenario that employees and associates might encounter. As such, employees and associates are always expected to exercise sound judgement. This policy is not intended to modify the terms of your employment or associate agreement, but rather to guide and assist in understanding the expectations set for us, and to provide resources for advice and assistance when needed. 

Upholding integrity: preventing bribery and corruption 
Digital Bricks firmly upholds a commitment to maintaining legal and ethical standards in all areas of our business operations. This commitment transcends mere cultural values; it is a fundamental legal obligation. Engaging in bribery constitutes a criminal act, and any corrupt practices not only put us, our employees, and our associates at risk of legal repercussions, such as prosecution, fines, and imprisonment, but also jeopardise the reputation of Digital Bricks Learning. Our policy is to conduct all business dealings with honesty, steering clear of corrupt practices or bribery to gain unfair advantages. We recognise that any benefit, whether financial or otherwise, could be construed as a bribe if offered with the intention of influencing an unfair outcome. 

Mitigating risks of fraud and bribery 
Bribery, particularly in procurement decisions, entails any form of advantage that results in an improper benefit. For instance, any advantage that unduly sways a decision maker to favour Digital Bricks Learning in contract awards can be deemed a bribe. It is crucial to assess whether any offered advantage could be perceived as bribery. This includes benefits given personally to a decision maker or a group, leading them to violate their duty of good faith to a third party. Engaging in fraudulent practices, which can distort, damage, or unduly influence procurement, selection, or contract execution, is categorically prohibited. These practices encompass any actions that deceive or mislead, whether done recklessly or intentionally, any party involved in these processes. 

While Digital Bricks acknowledges that the exchange of gifts, entertainment, and hospitality can be a part of establishing normal business relations, it’s essential to be aware of when such exchanges may imply improper influence or conflicts of interest. In certain cases, these exchanges might be construed as bribery, which is illegal and can lead to criminal charges for both the individuals and the company. For guidance or in cases of uncertainty, please consult with the Director. 

The obligation to prevent, identify, and report any instances of bribery or corruption extends to everyone affiliated with Digital Bricks Learning. Should you need to report any misconduct or seek clarification regarding potential bribery or corruption, please reach out to the Director. Reports can also be made confidentially to the Director at hello@digitalbrickslearning.com.