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Anti-Bribery and Corruption Policy

1. Policy Statement
1.1 PGI Services LTD is committed to conducting all business with honesty and integrity. We operate a zero-tolerance approach to bribery and corruption and are dedicated to acting professionally, fairly, and ethically in all business activities and relationships. We maintain and enforce effective systems to counter bribery.
1.2 We uphold all relevant anti-bribery and anti-corruption laws in every jurisdiction where we operate. This includes strict compliance with the UK Bribery Act 2010, both domestically and abroad.
1.3 The purpose of this policy is to:
  • Define responsibilities for preventing bribery and corruption.
  • Provide guidance to our workers on how to identify and address such issues.
1.4 Bribery and corruption are criminal offences. Individuals found guilty may face up to 10 years in prison, and PGI Services LTD may face unlimited fines and reputational damage. We take our legal responsibilities seriously.
1.5 In this policy, a “third party” includes anyone a worker may come into contact with during the course of work—clients, suppliers, agents, officials, etc.
2. Who is Covered by the Policy?
This policy applies to all employees, officers, directors, consultants, contractors, trainees, agency staff, volunteers, interns, sponsors, and any other individuals or entities associated with PGI Services LTD or its subsidiaries worldwide.
3. What is Bribery?
A bribe is an offer or receipt of a gift, payment, or advantage intended to influence business decisions or secure personal or commercial gain.
Examples:
  • Offering a Bribe: Providing a client with event tickets conditional on doing business.
  • Receiving a Bribe: A supplier hires your relative in return for business influence.
  • Bribing an Official: Making extra payments to customs officials for faster clearance.
4. Gifts & Hospitality
4.1 This policy does not prohibit modest and lawful hospitality.
4.2 Gifts and hospitality are acceptable only if:
  • They are not intended to influence business decisions.
  • They comply with local laws.
  • They are in the name of PGI Services LTD.
  • They exclude cash or cash equivalents.
  • They are appropriate in value and openly given.
4.3 Cultural norms vary. Apply judgment and ensure gifts are reasonable and justified.
5. What is Not Acceptable?
You must not:
  • Offer or accept bribes, including payments or gifts to gain business.
  • Make or accept facilitation payments to officials.
  • Accept or offer anything that appears to secure improper advantages.
  • Retaliate against those who report bribery or corruption concerns.
6. Facilitation Payments & Kickbacks
6.1 PGI Services LTD does not permit facilitation payments or kickbacks.
6.2 If you’re asked to make a payment, assess its legitimacy, request a receipt, and raise concerns with the compliance manager.
6.3 Avoid any behaviour that might suggest such payments will be made or accepted.
7. Donations
PGI Services LTD may make charitable or political contributions, but never to secure business advantages. All donations require prior approval from the compliance manager.
8. Your Responsibilities
8.1 Read and understand this policy.
8.2 Avoid any activity that may breach this policy.
8.3 Report any suspicion of bribery or conflict of interest to your manager or the compliance manager immediately.
8.4 Breaches may result in disciplinary action or contract termination.
9. Record Keeping
9.1 Maintain clear and accurate financial records.
9.2 Log all gifts and hospitality received or given.
9.3 Follow the expenses policy when submitting claims.
9.4 Avoid off-the-record accounts or concealed payments.
10. How to Raise a Concern
If you suspect bribery or corruption, raise the issue with your manager or the compliance manager promptly.
11. What to Do If You Are a Victim
Report immediately to the compliance manager or use the confidential helpline if you’re offered or asked to give a bribe.
12. Protection
12.1 PGI Services LTD supports openness. You will not suffer retaliation for reporting concerns in good faith.
12.2 If you believe you’ve been treated unfairly for reporting concerns, raise the matter with the compliance manager or through the Grievance Procedure.
13. Training & Communication
13.1 This policy is part of employee induction. Ongoing training is provided to all workers.
13.2 Our zero-tolerance stance must be communicated to all suppliers, partners, and contractors.
14. Responsibility for the Policy
14.1 The Managing Director has overall responsibility for ensuring compliance.
14.2 The compliance manager oversees day-to-day implementation and effectiveness.
15. Monitoring & Review
15.1 The compliance manager regularly reviews the policy and suggests improvements.
15.2 All workers must help ensure the policy’s success by reporting concerns.
15.3 Suggestions for improvement are welcome and should be directed to the compliance manager.
15.4 This policy may be updated and does not form part of any employment contract.
Potential Risk Scenarios: ‘Red Flags’
Watch for these signs and report them:
  • Third parties known for unethical practices or close ties to officials.
  • Requests for unorthodox payments, especially in cash or offshore.
  • Demands for extravagant gifts or entertainment.
  • Invoices that are unclear, inflated, or unusually structured.
  • Third parties insisting on informal or undocumented agreements.
  • Offers of gifts or favours that seem overly generous or suspicious.
Managing Director – Rajwinder Kaur
PGI Services LTD
Gravesend, Kent