Anti Bribery Policy

Our Corporate Commitment

We carry out our business honestly, ethically and with respect for the rights and interests of our employees, sub-contractors and suppliers.

Anti-Bribery and Corruption Statement

 AVA Energy has a zero tolerance of bribery and corruption and is committed to acting professionally, fairly and with integrity in all business dealings and relationships.  The AVA Energy Anti-Bribery and Corruption Policy extends to all the AVA Energy business dealings and transactions in all countries in which it or its subsidiaries and associates operate. This policy is given force within the AVA Energy in a detailed anti-bribery and corruption program which is regularly revised to capture changes in law and best practices as well as changes in the AVA Energy businesses.  All directors, employees, business partners, agents, sub-contractors, consultants and any other party engaged by the AVA Energy are required to comply with this policy without exception.

1. In this Anti-Bribery and Corruption Policy:

1.1. AVA means AVA Energy and all its associated subsidiaries and employees.

1.2   Policy means this Group Anti-Bribery and Corruption Policy.

1.3   Third Party means any individual or organisation the AVA Energy comes into contact with in its business dealings and relationships and includes, consultants, contractors, trainees, seconded staff and agency staff, volunteers, interns, sponsors, actual and potential clients, customers, suppliers, business contacts, agents and advisors; including their advisors, representatives and officials and all persons or organisations associated with or overseen by the AVA Energy or Third Party.

2.  The main purpose of this Policy is to set out the AVA Energy and its Third Parties’ responsibility in observing and upholding the AVA Energy’s position on bribery and corruption and to provide information and guidance to Third Parties. It is therefore essential for this Policy to be communicated to all business and employees overseen by Third Parties.

3. In order for the AVA Energy to maintain its high ethical standards and to protect the AVA Energy against any allegation of bribery or corruption it is required of all AVA Energy employees and Third Parties to comply with the rules and principles contained within this Policy and anti-bribery laws.

4. The AVA Energy will uphold all laws that may be relevant to the countering of bribery and corruption in all jurisdictions in which we operate. However, we remain bound by the laws of the United Kingdom in respect of the AVA Energy’s conduct both in the United Kingdom and abroad.

Who is covered by this Policy?

This Policy applies to all AVA Energy employees at all levels and grades, volunteers and all Third Parties associated with or overseen by the AVA Energy.

What is Bribery?

1. In essence the Bribery Act defines bribery as the offer, promise, giving, demanding or acceptance of a financial or other advantage to any person whatsoever as an inducement for an action which is improper, illegal, unethical or a breach of trust.

2.  It is irrelevant for the purpose of bribery, whether the payee or recipient of the act of bribery work in the public or private sector.

3. The definition of giving or receiving a bribe is all inclusive. It applies to all Third Parties and employees. There are no exceptions.

4. There are four main offences under the Bribery Act:

4.1 Giving of a bribe;

4.2   Receiving of a bribe;

4.3   Bribing of a foreign public official; and

4.4   Strict liability for commercial organisations if any person associated with that commercial organisation is guilty of an offence.


1. The prevention, detection and reporting of bribery and corruption are the responsibility of all AVA Energy employees and its Third Parties. All employees and Third Parties are required to avoid and prevent any activity that might lead to, or suggest, a breach of this Policy.

2. If it is believed or suspected that a conflict with this Policy has occurred, or may occur in the future Third Parties and AVA Energy employees must notify the AVA Energy Company Secretary as soon as possible.

3. Any AVA Energy employee who breaches this Policy will face disciplinary action, which could result in dismissal for gross misconduct. AVA Energy reserves its right to terminate any contractual relationship with a Third Party if it breaches this Policy.

4.  AVA Energy will and it is required of all its Third Parties to:

4.1 Ensure that top-level management within its organisation are committed to preventing bribery and corruption and that a culture is fostered within its organisation in which bribery and corruption are never acceptable;

4.2 Ensure that it periodically and in an informed manner assesses the nature and extent of its exposure to potential external and internal risks of bribery and corruption on its behalf;

4.3 Ensure that it applies due diligence procedures, taking a proportionate and risk based approach, in respect of persons who perform or will perform services on its behalf, in order to mitigate identified bribery and corruption risks;

4.4 Ensure that robust and effective bribery and corruption preventative policies, practices and procedures are implemented and enforced;

4.5 Ensure that its bribery and corruption prevention policies and procedures are embedded and understood throughout its organisation through internal and external communication, including training, that is proportionate to the risks it faces, and communicated to Third Parties;

4.6 Ensure that it periodically and in an informed manner monitors and reviews procedures and practices designed to prevent bribery and corruption by persons associated with it and makes improvements where necessary; and

4.7 Ensure that it will keep financial records and have appropriate internal controls in place for business reasons for making payments to third parties.

Further Information and Support

Should you have any doubt as to the definition of this Policy and/or require any clarification you should contact the AVA Energy Group Company Secretary, Ritina Shukla at:   Ritina.shukla@avaenergy.co.uk

How to Raise an Issue

You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. Concerns should be reported to the Group Company Secretary in the manner stipulated above.

Gifts and Hospitality

The AVA Energy strictly prohibits accepting significant gifts or any other business courtesy (including benefits or discounts that are not made available to all employees) from any of our partners, clients, suppliers or competitors.

We appreciate giving and receiving modest gifts and hospitality may foster goodwill in a range of business relationships without any intention to prejudice or influence current or future business dealings.

Any such gifts or hospitality must, however, be reasonable, appropriate, limited in value and frequency and in keeping with appropriate business “custom and practice” and in accordance with all applicable laws.

Gifts and hospitality designed to induce or reward improper conduct or where they might compromise – or be perceived to compromise – the recipient’s judgment or integrity are not permitted.

As set out in the Employee Code of Conduct all Employees, all business dealings should be open and honest and transactions should be in the best interests of the Company and the customers.

  1. To ensure this, you should not offer or provide, to customers or prospective customers, directly or indirectly, any gift, entertainment or reimbursement of expenses of more than nominal value or that exceeds customary courtesies for that time and place. Nor should you offer or provide, directly or indirectly, any material, equipment or services to any individual in a position to make or influence any business or governmental decision affecting the Company. Guidelines for the value of gifts, hospitality and entertainment are set out and form part of the AVA expense policy set out in the AVA Employee Handbook.

2.  Conversely, you should not solicit or accept, directly or indirectly, any payment, loan, services, equipment or any other benefit or thing of value, or any gift, entertainment or reimbursement of expenses of more than nominal value or that exceeds customary courtesies for that time and place from suppliers or customers, or from any Company, individual or institution that furnishes or seeks to furnish supplies or services to the Company, or from anyone else with an actual or prospective business relationship with the Company.

3. You must remain scrupulously free from obligation to customers, suppliers and vendors. Accordingly, you should not requisition order, approve or otherwise participate in the purchase of goods or services on behalf of the Company from any person or entity if you or any member of your family or household has a substantial financial interest in the supplier or vendor.

4. We recognise that personal friendships may develop between customers and employees. Those friendships may benefit the Company and you. Any relationship between a customer and an employee likely to jeopardise business relations and destroy market or client confidence in the Company is not, however, acceptable. Use your common sense and avoid any relationships which might compromise your career and the Company. If in doubt, always ask your Manager for advice.

Business Integrity

Protected Disclosures (Whistleblowing)

Our Staff Handbook provides a full procedure in respect of protected disclosure (“whistleblowing”) and any employee with ethical or professional concerns is encouraged to report these in full confidence under our procedure.  The Public Interest Disclosure Act 1998 prevents employees from suffering a detriment or having their contract terminated for ‘whistle blowing’ and we take very seriously any concerns which an employee may raise under this legislation.

Conflict of Interest

Any personal interest which may prejudice, or might reasonably be deemed by others to prejudice, the impartiality of employees, must be formally declared to a senior manager for formal review by the company. Examples of this include owning shares in business partners and personal or family involvement in trading contracts.

Responsibility and Implementation

Responsibility for the compliance of AVA Energy with this policy lies ultimately with the Board and all managers.

All AVA staff share responsibility for maintaining and promoting the company’s integrity standards. While this policy describes the principles under which we operate, it cannot cover every contingency. We therefore expect our staff to use their judgment not just to avoid poor practice but to promote best practice in accordance with ITHR’s commitment to high standards of integrity and all staff are encouraged to refer any issues and anxieties they may have which might compromise our business ethics or practices.

Our Board and managers will make sure that this Policy is communicated to all employees and as part of our Induction programmes for new employees.

Review and Update

This policy will be reviewed annually and updated where appropriate in accordance with prevailing legislation.


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