Anti-Bribery Policy

Our commitment

Blue Pulse Ltd prohibits bribery in all its forms.

This commitment is not negotiable against commercial advantage. We would rather lose a contract, client, accreditation or business opportunity than obtain or retain one through an improper payment, benefit or advantage.

Everyone who works for or represents Blue Pulse Ltd is expected to uphold this standard. This includes our directors, employees, managers, associate trainers, subcontractors, agents, consultants, suppliers and other business associates acting on our behalf.

Purpose and scope

This policy communicates Blue Pulse Ltd’s commitment to preventing, detecting and responding to bribery.

It applies to all activities undertaken by or on behalf of Blue Pulse Ltd, in every location in which we operate. It covers conduct involving the public, private and not-for-profit sectors.

Prohibition of bribery

No person acting for or on behalf of Blue Pulse Ltd may directly or indirectly:

• offer;

• promise;

• give;

• request;

• accept; or

• solicit

an improper financial or non-financial advantage as an inducement or reward for a person to perform, improperly perform, delay or refrain from performing their duties.

This prohibition applies regardless of:

• the value of the advantage;

• whether it is provided directly or through another person;

• whether the other party is a public official or a private person;

• where the conduct takes place; or

• whether the intended beneficiary is Blue Pulse Ltd or another person or organisation.

Facilitation payments and kickbacks

Facilitation payments are prohibited.

A facilitation payment is an unofficial payment made to secure or accelerate a routine action to which a person or organisation is already entitled.

Kickbacks in any form are also prohibited.

Where a payment is demanded in circumstances involving an immediate risk to personal safety, the individual may take reasonable action to protect themselves. The incident must be reported as soon as it is safe to do so. A person who makes such a payment solely to protect personal safety and reports it promptly will not be disciplined for doing so.

Compliance with applicable laws

Blue Pulse Ltd requires compliance with all anti-bribery and anti-corruption laws applicable to its activities.

These include applicable legislation in the Republic of Cyprus and, where relevant to our international activities and relationships, legislation with extraterritorial application, including the UK Bribery Act 2010.

Where this policy establishes a stricter standard than the minimum required by applicable law, the requirements of this policy will apply, provided that doing so does not conflict with mandatory legal obligations.

Gifts and hospitality

Gifts, hospitality and similar benefits may only be offered or accepted where they are:

• lawful;

• reasonable and proportionate;

• transparent;

• given for a legitimate business purpose;

• properly approved where approval is required; and

• accurately recorded.

They must never be offered or accepted where they are intended, or could reasonably be perceived, to influence a decision improperly, secure preferential treatment or create an obligation.

Cash gifts and cash equivalents must not be offered or accepted.

Donations and sponsorships

Charitable donations, community contributions and sponsorships must be made transparently, for legitimate purposes and in accordance with the organisation’s approval and record-keeping requirements.

They must not be used to obtain an improper advantage, influence a decision or conceal a payment to an individual or organisation.

Blue Pulse Ltd does not make political donations.

Conflicts of interest

All actual, potential and perceived conflicts of interest must be disclosed promptly.

Individuals acting for or on behalf of Blue Pulse Ltd must not participate in a decision or activity where their personal, financial, family or other interests could improperly influence, or appear to influence, their judgement.

Conflicts of interest must be assessed and appropriately managed. Failure to disclose a relevant conflict may constitute a breach of this policy.

Integrity of training, assessment and certification

Blue Pulse Ltd is committed to protecting the integrity of its training, assessment and certification activities.

No certificate, qualification, assessment result, accreditation record or attendance record may be:

• issued;

• altered;

• withheld;

• falsified; or

• backdated

in exchange for any payment, benefit, favour or other improper advantage.

Training and assessment decisions must be based solely on verified attendance, participation, performance and compliance with the applicable published requirements.

Any attempt to influence these decisions improperly must be refused and reported.

Public funding, grants and tenders

All information submitted by Blue Pulse Ltd in connection with grants, subsidies, tenders, contracts or public funding must be accurate, complete and verifiable.

This includes information concerning:

• attendance;

• programme delivery;

• expenditure;

• costs;

• procurement;

• outputs; and

• supporting records.

No improper advantage may be offered, promised, given, requested or accepted in connection with the application, award, administration, implementation, verification or audit of public funding.

Business associates and third parties

Blue Pulse Ltd expects its associate trainers, subcontractors, agents, consultants, suppliers and other business associates to conduct their activities with integrity and in accordance with applicable anti-bribery laws.

Risk-based due diligence may be undertaken before entering into or continuing certain business relationships.

Appropriate anti-bribery requirements may be included in contracts and agreements. Blue Pulse Ltd reserves the right to suspend or terminate a relationship where bribery, suspected bribery or a serious breach of applicable anti-bribery requirements is identified.

Raising concerns

Blue Pulse Ltd encourages the reporting of:

• attempted, suspected or actual bribery;

• requests for improper payments or benefits;

• suspicious conduct or transactions;

• breaches of this policy;

• failures in anti-bribery controls; and

• concerns regarding retaliation.

Reports may be made in good faith or on the basis of a reasonable belief. A person does not need to have complete evidence before raising a genuine concern.

Reports will be treated as confidentially as reasonably possible, taking account of the need to investigate the matter fairly and comply with legal obligations.

Where permitted by applicable law and the available reporting arrangements, concerns may be raised anonymously.

Protection against retaliation

Blue Pulse Ltd prohibits retaliation against any person who:

• raises a concern in good faith or on the basis of a reasonable belief;

• refuses to participate in bribery;

• refuses to make an improper payment;

• cooperates with an investigation; or

• provides information relating to a suspected breach.

This protection applies even where a refusal results in the loss of business, delay, additional cost or another commercial disadvantage to Blue Pulse Ltd.

A person will not be penalised merely because a genuine concern is investigated and ultimately found to be unsubstantiated.

Retaliation, intimidation, discrimination or victimisation against a reporting person is itself a serious breach of this policy.

Investigations

Blue Pulse Ltd will assess concerns promptly and proportionately.

Investigations will be conducted objectively and, where appropriate, may involve independent professional advisers, external investigators, legal counsel or competent authorities.

Everyone acting for or on behalf of Blue Pulse Ltd is expected to cooperate with legitimate investigations and preserve relevant records.

No person may conceal, destroy, alter or falsify information relating to an investigation or suspected breach.

Consequences of non-compliance

Failure to comply with this policy is a serious matter.

Employees may be subject to disciplinary action, up to and including dismissal, in accordance with applicable employment procedures and legislation.

Contracts or engagements with associate trainers, subcontractors, agents, consultants, suppliers and other business associates may be suspended or terminated.

Where criminal conduct is suspected, Blue Pulse Ltd may report the matter to the relevant authorities and cooperate with any official investigation.

Bribery may expose both individuals and organisations to criminal penalties, financial loss, reputational damage and the loss of contracts, certifications, accreditations, authorisations or eligibility for public funding.

Responsibilities

The governing body and top management are responsible for approving and supporting Blue Pulse Ltd’s anti-bribery commitments.

Management is responsible for:

• promoting a culture of integrity;

• providing appropriate resources;

• implementing anti-bribery controls;

• ensuring relevant personnel receive information and training;

• responding appropriately to reported concerns; and

• supporting continual improvement.

The anti-bribery function is responsible for overseeing and advising on the organisation’s anti-bribery arrangements and monitoring their implementation.

All personnel and business associates are responsible for:

• complying with this policy;

• acting honestly and ethically;

• declaring relevant conflicts of interest;

• complying with applicable gifts and hospitality requirements;

• reporting bribery concerns; and

• cooperating with legitimate reviews and investigations.

Awareness and communication

This policy is communicated to personnel and made available to relevant business associates and interested parties.

Appropriate anti-bribery information, awareness and training are provided according to role, responsibility and identified risk.

Blue Pulse Ltd seeks to ensure that individuals understand both the prohibition of bribery and the practical actions expected of them.

Continual improvement

Blue Pulse Ltd is committed to maintaining and continually improving its Anti-Bribery Management System.

Anti-bribery objectives, controls and arrangements are reviewed in light of:

• organisational changes;

• changes in applicable legislation;

• operational experience;

• reported concerns;

• investigation findings;

• audit results; and

• changes in bribery risk.

Policy governance

This policy is approved by the governing body of Blue Pulse Ltd and is reviewed at least annually and whenever a significant change occurs in the organisation, its activities, applicable obligations or bribery risks.

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Contact us

Questions concerning this policy or requests for further information may be directed to Blue Pulse Ltd through the official contact details published on our website.

Concerns involving suspected bribery should be submitted through the organisation’s designated confidential reporting channels. A person may also report suspected criminal conduct directly to the appropriate competent authority.