As part of the Gardiner & Theobald Group, Fairway has a zero tolerance of bribery and corruption.
Bribery is “the giving, receiving, soliciting or promising of money, a gift or anything else of real or implied value as an inducement to do something that is dishonest, illegal or a breach of trust in order to secure business or a business advantage”.
Whilst we respect the rules by which others conduct their own business, these are the principles by which we conduct our business:
- We will carry out our business fairly, honestly, openly and with integrity.
- We will not make bribes, nor will we condone the offering of bribes on our behalf.
- We will not accept bribes, nor will we agree to them being accepted on our behalf.
- We will avoid appointing others to provide services for us or on our behalf who do not share these principles and who may harm our reputation.
- We will set out our processes for avoiding bribery and keeping to and supporting our values.
- We will keep clear and updated records.
- We will make sure that all members of the firm and our business partners know our principles.
- We will regularly review and update our programme and processes as needed.
- We will keep to these principles even when it becomes difficult.
- We will at all times act with integrity and avoid conflict of interest and any actions or situations that are inconsistent with our professional obligations.
The Management Board recognises that any violition of anti-bribery and corruption laws could subject the Members of the Firm to severe penalties including unlimited fines and imprisonment.
The Management Board requires the following procedures to be implemented and maintained:
- Strict compliance with this policy.
- Implementation of an Anti-Bribery Programme.
- Training to allow recognition of, and avoidance of, bribery. The internet-based training resource is compulsory for everyone in the Gardiner & Theobald Group in every UK and non UK office. The provision of appropriate training is a key feature of our obligations under the Act and one which is monitored and audited.
- Vigilance and reporting of any suspicion of bribery, immediately to the Group Managing Partner.
- Rigorous investigation of any alleged bribery.
- Firm disciplinary action against anyone involved in bribery.
- All of our business partners must be informed of this policy and must comply with this policy.
The policy applies to all of the Group business dealings and transactions. It applies to all members of the Group and our business partners. This policy applies in all countries where we carry out business.
Our policy was approved by the Management Board at a meeting on 14 February 2011 and is revalidated by the Management Board on an annual basis. The policy was last revalidated at the Management Board held on 20 June 2016.
Download a full copy of our anti-bribery policy and related business rules.