Effective Date: 14/12/2024

The Owen Project CIC (“the Company”) is committed to conducting its activities in an ethical, transparent, and lawful manner. As part of our commitment to maintaining the highest standards of integrity, we have implemented this Anti-Bribery and Corruption Policy. This policy sets out the Company’s zero-tolerance stance towards bribery and corruption and establishes the measures we take to prevent and address these practices in our operations.

1. Purpose

The purpose of this policy is to:

• Ensure that The Owen Project CIC operates in a lawful, ethical, and transparent manner, free from bribery and corruption.
• Provide clear guidelines on what constitutes bribery and corruption and the actions that will be taken if such behavior is identified.
• Protect the reputation and integrity of The Owen Project CIC by preventing bribery and corruption in all business dealings and relationships.
• Ensure compliance with relevant anti-bribery and anti-corruption laws, including the Bribery Act 2010 (UK), and other applicable international regulations.

2. Scope

This policy applies to all individuals and organizations associated with The Owen Project CIC, including:

• Employees
• Volunteers
• Board members
• Contractors and consultants
• Business partners and suppliers
• Any third parties acting on behalf of the Company

3. Definitions

• Bribery: Offering, giving, receiving, or soliciting something of value to influence the actions of an individual or organization in a way that is improper or unethical.
• Corruption: Any form of unethical or illegal conduct that involves the misuse of power or influence for personal or organizational gain. This includes bribery but may also involve fraud, kickbacks, or other illicit financial transactions.

4. Prohibited Conduct

The Owen Project CIC prohibits the following actions under all circumstances:

• Offering or Accepting Bribes: Offering, giving, or receiving bribes in any form, whether direct or indirect, to influence decisions or gain an improper advantage.
• Facilitation Payments: Making or accepting payments to expedite or secure a service or process that should otherwise be completed according to established procedures.
• Kickbacks: Offering or accepting any form of illegal payment or compensation for the referral of business or services.
• Conflicts of Interest: Engaging in actions where personal interests interfere with the objectivity of decisions made in the best interest of The Owen Project CIC.
• Corrupt Practices: Engaging in or benefiting from any illegal or unethical practices related to bribery or corruption, including the use of intermediaries or agents to facilitate bribery or corrupt conduct.

5. Responsibilities

All individuals and organizations associated with The Owen Project CIC are expected to:

• Understand the Policy: Familiarize themselves with this Anti-Bribery and Corruption Policy and ensure compliance in all activities conducted on behalf of The Owen Project.
• Report Concerns: Report any suspected bribery, corruption, or unethical behavior immediately. This can be done through The Owen Project’s Whistleblowing Policy or to a designated person within the organization.
• Avoid Conflicts of Interest: Disclose any potential or actual conflicts of interest that could lead to biased decisions or actions.
• Follow Procedures: Adhere to the Company’s internal procedures, financial controls, and governance practices designed to prevent bribery and corruption.

6. Gifts, Hospitality, and Entertainment

The Owen Project CIC recognizes that there may be occasions where offering or accepting gifts, hospitality, or entertainment is appropriate in a professional context. However, all such activities must be conducted transparently, ethically, and within the following guidelines:

• Reasonable and Proportionate: Gifts, hospitality, or entertainment should be reasonable, proportionate, and directly related to business purposes.
• Transparent: Any gifts or hospitality offered or received must be clearly documented and reported to The Owen Project’s management team.
• Not for Influence: Gifts or hospitality should never be offered or accepted with the intent to influence a decision or gain an improper advantage.
• Monetary Gifts: Cash gifts or equivalent items (e.g., vouchers) should not be offered or accepted under any circumstances.

7. Third-Party Relationships

The Owen Project CIC requires that all third parties, including business partners, suppliers, and contractors, comply with the same high ethical standards. We will:

• Conduct Due Diligence: Perform appropriate checks to assess the risk of bribery or corruption when engaging with new third parties, ensuring they have policies in place to prevent such activities.
• Include Anti-Bribery Clauses in Contracts: Ensure that all contracts with third parties include clauses prohibiting bribery and corruption, and require them to adhere to this policy.
• Monitor Compliance: Regularly review the conduct of third-party relationships to ensure compliance with this Anti-Bribery and Corruption Policy.

8. Reporting and Whistleblowing

The Owen Project CIC encourages individuals to report any suspected violations of this policy. Reports can be made confidentially and without fear of retaliation.

• How to Report: Concerns can be raised to a manager, supervisor, or the designated Whistleblowing Officer. The Company’s Whistleblowing Policy outlines the reporting process and protections for whistleblowers.
• Investigation of Reports: All reported concerns will be investigated thoroughly, and appropriate action will be taken, which may include disciplinary measures, legal action, or termination of relationships with third parties involved in unethical conduct.
• No Retaliation: The Owen Project CIC has a zero-tolerance policy for retaliation against anyone who reports bribery or corruption in good faith. Any such retaliation will be treated as a serious violation of Company policy.

9. Disciplinary Action

Any employee, volunteer, or individual associated with The Owen Project CIC found to be in breach of this Anti-Bribery and Corruption Policy will be subject to disciplinary action, which may include:

• A formal written warning.
• Suspension or termination of employment or contract.
• Legal action, where appropriate, including reporting to relevant authorities for prosecution.

The severity of the disciplinary action will be determined by the nature of the violation, the intent of the individual, and the potential harm caused to The Owen Project CIC.

10. Training and Awareness

To ensure that all individuals associated with The Owen Project CIC understand their responsibilities, the Company will:

• Provide regular training on anti-bribery and anti-corruption laws and the Company’s policies.
• Make this policy easily accessible to all employees, volunteers, board members, contractors, and other stakeholders.
• Encourage a culture of integrity by promoting awareness of the risks of bribery and corruption and the importance of ethical behavior.

11. Monitoring and Review

The Owen Project CIC will regularly review this Anti-Bribery and Corruption Policy to ensure that it remains up-to-date and effective in preventing bribery and corruption. The review process will include:

• Monitoring the effectiveness of the policy and its implementation.
• Ensuring compliance with applicable laws and regulations.
• Addressing any issues or concerns raised by employees, partners, or other stakeholders.

12. Contact Information

If you have any questions regarding this Anti-Bribery and Corruption Policy or if you need to report an issue, please contact:

Jessica Owen or Luke Owen
Email: theowenproject@outlook.com

By engaging with The Owen Project CIC, you acknowledge that you have read, understood, and agree to comply with this Anti-Bribery and Corruption Policy. Thank you for your commitment to upholding the integrity and values of our organization.