Anti-Bribery and Corruption Policy

POLICY AND PRINCIPLES

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Introduction

BDM Construction values its reputation and is committed to maintaining the highest level of ethical standards in the conduct of its business affairs. The actions and conduct of the company’s staff, as well as others acting on the company’s behalf, are key to upholding these standards.

 

The purpose of this document is to set out the company’s policy in relation to bribery and corruption. The policy applies strictly to all employees, directors, agents, consultants, contractors, and to any other people or bodies associated with BDM Construction, across all regions, areas, and functions.

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Understanding and Recognising Bribery and Corruption

Acts of bribery or corruption are designed to influence an individual in the performance of their duties and incline them to act in a way that a reasonable person would consider dishonest in the circumstances.

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Bribery can be defined as offering, promising, or giving a financial (or other) advantage to another person with the intention of inducing or rewarding that person to act—or for having acted—in a way which a reasonable person would consider improper. Corruption is any form of abuse of entrusted power for private gain and may include, but is not limited to, bribery.

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Bribes are not always in the form of cash. Gifts, hospitality, and entertainment can also constitute bribes if they are intended to influence a decision.

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Penalties

The Bribery Act 2010, which came into force on 1 July 2011, makes bribery by individuals punishable by up to ten years’ imprisonment and/or an unlimited fine. If the company is found to have participated in bribery or is found to lack adequate procedures to prevent bribery, it may also face an unlimited fine.

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A conviction for a bribery or corruption-related offence could have severe reputational and financial consequences for the company.

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BDM Construction will not tolerate bribery or corruption in any form.

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The company prohibits the offering, giving, solicitation, or acceptance of any bribe or corrupt inducement, whether in cash or any other form:

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• To or from any person or company, whether a public official or body, or a private person or entity;

• By any employee, director, agent, consultant, contractor, or other party acting on behalf of the company;

• In order to obtain or retain any commercial, contractual, or regulatory advantage for the company in a manner that is unethical; or

• To gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual.

 

This policy is not intended to prohibit the following practices, provided they are appropriate, proportionate, and properly recorded:

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• Normal hospitality, in line with the company’s Corporate Entertainment Policy;

• Expediting a process which is open to all upon payment of a fee; and/or

• Providing resources to assist a decision-maker in their duties, provided it is solely for that purpose.

 

If you are unsure whether a particular action might breach this policy or the law, it is essential to raise the matter with your Head of Department. Further guidance may also be sought from the Managing Director.

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BDM Construction will thoroughly investigate any actual or suspected breach of this policy, or its spirit. Employees found in breach may face disciplinary action, which could result in dismissal.

 

Key Risk Areas

Bribery risks can arise in several areas of the company. Particular attention should be given to:

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• Excessive gifts, entertainment and hospitality: While some are acceptable, anything used to exert improper influence is prohibited.

• Facilitation payments: These are small, unofficial payments to speed up routine actions. BDM Construction does not tolerate or excuse such payments.

• Reciprocal agreements (‘quid pro quo’): These are not acceptable unless legitimate, documented, and approved by management.

• Third-party actions: BDM Construction can be held liable for actions taken by agents, contractors, and consultants acting on its behalf. Due diligence is essential, and any payments must be properly authorised and recorded.

• Record keeping: Robust, transparent controls must be in place to prevent concealment of bribes or corrupt behaviour.

 

Employee Responsibility and Reporting Concerns

Preventing, detecting, and reporting bribery or corruption is the responsibility of all employees. If you become aware of or suspect that any activity or conduct may involve bribery or corruption, you are under a duty to report it. Concerns should be reported to the Managing Director.

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Signed by the Directors  |  April 2025

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