Barras Capital Management Limited (the “Firm”) is committed to ensuring that it, its directors, employees, agents and anyone contracted to it comply with the requirements of the UK Bribery Act 2010.
Our commitment to anti-bribery and anti-corruption business integrity is a core aspect of our business mission and informs all our operations and decision making. We take a zero-tolerance approach toward bribery and corruption and ensure that this approach is consistent throughout our business delivery and partnerships. We comply with all laws, both in the UK and the jurisdictions in which we conduct business.
We believe that our efforts to identify and mitigate integrity risks help ensure the success and sustainability of our business strategy. We value our ethical business reputation and recognise that our exposure to bribery and corruption goes beyond potential civil and criminal penalties and would not only affect adversely our good repute but also facilitate unethical behaviour which has an impact on the wider community and the economy.
- In our efforts to prevent the Firm, or anyone in the Firm, from committing and/or facilitating bribery and corruption the measures we have taken include:-
- Implementing a clear anti-bribery policy;
- Communicating the policy and procedures to staff and relevant contractors;
- Communicating the Firm’s zero tolerance approach to bribery and corruption to staff and relevant contractors;
- Providing training to all members of staff and relevant contractors on the Bribery Act 2010 and on how to detect and report bribery and corruption;
- Investigating all suspicions of bribery and corruption and cooperate fully with the relevant authorities during an investigatory process;
- Monitoring the Firm’s compliance with the policy through compliance monitoring, transaction reviews and ad-hoc checks;
- Implementing and communicating a clear gifts, benefits and hospitality review and approval procedure;
- Implementing and communicating a clear whistle-blowing policy and procedure;
- Encouraging staff and relevant contractors to communicate concerns and provide clear guidance on how concerns can be escalated and reported;
- Requiring all staff and relevant contractors to agree to abide by the Firm’s anti-bribery policy and related procedures;
- Taking disciplinary procedures against staff and relevant contractors who are non-compliant;
- Providing training to relevant staff and contractors on the conduct rules of the FCA’s Senior Management & Certification Regime (“SM&CR”), which include the requirement to act with “honesty and integrity”, and to discharge their role with due skill, care and diligence; and
- Risk-assessing the Firm’s business for bribery and corruption, covering geographical risk, client risk, products and services risks, and taking into account any contractor and partnership arrangements.
We require all directors, staff, relevant contractors and anyone working in the Firm’s name:-
- not to offer, promise or give any advantage to any individual to induce an improper function or action;
- not to request, agree to receive or accept any bribe, facilitation or other form of corrupt payment. Not only are such payments in violation of the law but are also wholly incompatible with our mission to promote our core ethical values.
The Firm is committed to taking all reasonable steps to mitigate integrity risks and will make improvements where necessary to limit our exposure to integrity risks stemming from bribery and corruption.