Anti-Bribery Statement

Rowleys Commercial Energy Assessment Limited is committed to carrying out business fairly, honestly and openly. This means we have a zero tolerance towards bribery. We will never permit or authorise the offering, making or receiving of a bribe. There are no exceptions to this policy.

The policy’s purpose is to:

  • Set out our general policy in relation to bribery, of which all employees, contractors and other workers need to be aware.

In this policy references are made to the Company Director, Mr Peter Rowley, and the General Manager, Mr Douglas Hough. In the absence of either, all matters must be referred without undue delay to the other.

Who does this policy apply to?

This policy applies to everyone who works for us at whatever level. It will include all Directors, managers, employees (whether permanent or on fixed term contracts, full time or part-time etc.), as well as anyone who is not an employee (such as consultants, sub-contractors, agents, representatives).

Consequences of breaches of the policy for our employees and partners

Bribery is a crime. All of you, whether you are employees or Directors, if you offer, make or receive a bribe you will be breaking the law. We can also be liable for your activities. Bribery carries a sentence of up to 10 years in jail and the possibility of an unlimited fine. Any employee of ours who offers, makes or receive a bribe is very likely to be subject to disciplinary procedures (and this is likely to amount to gross misconduct and lead to dismissal in many cases).

Business consequences for us if bribery takes place

If we are involved in bribery (or those who work for us or with us or on our behalf, such as our clients, suppliers, agents or workers) there can be serious consequences. These include:

  • Damage to our reputation (including being subject to unfavourable press, TV and social media scrutiny);

  • Those who do business with us may cancel or not renew contracts with us;

  • Those who buy our goods and services may no longer do so;

  • If we are convicted of bribery we may have to pay over whatever amounts we have received from any business or contracts entered into pursuant to a bribe;

  • We could be stopped from trying to obtain work with some type of contracts with public organisations; and

  • We could be stopped from trying to obtain work from certain international bodies.

Consequences for those who provide goods and services to us

If a Company or a person who provides goods and/or services to us and has used bribery to do so we will normally wish to stop trading with them. For our agents and others acting on our behalf if they breach this policy, let alone offer, make or receive a bribe, we will wish to terminate our contracts immediately with them.

How we communicate this policy

This policy is made available in the following ways:

  • It is publicly available on our website at;

  • It is drawn to the attention of every new employee; and

  • Those working with us (employees and non-employees) who are most likely to be affected by bribery will receive additional training and support.

What you should do if you are subject to an offer of or making of a bribe or a request for a bribe?

If you are asked to make a bribe or you are offered a bribe (whether a mere offer or the actual making of it), you must of course refuse to make or receive the bribe. In normal circumstances:

  • You should explain our policy regarding bribery; and

  • You should refuse to make or receive (as the case may be) a bribe; and

  • Report the matter immediately to the General Manager who will also notify the Company Director.

We recognise that in certain circumstances you may feel that your personal safety is at risk if you are asked to make or receive a bribe. It may not be safe for you to explain our policy or to refuse or make the bribe. In such cases our first concern is for your safety. In such circumstances you will need to do what is necessary to protect yourself and then you will need to report what has occurred as soon as possible to the Company Director who will then notify the General Manager.

Recognising what is and what is not a bribe

Sometimes it is not always easy to recognise a bribe from a legitimate payment we need make or which we receive. Hospitality, gifts and charitable donations are not normally illegal and are all perfectly acceptable. They are also a normal way of establishing and building contacts and relationships with potential and actual customers as well as our suppliers.

To help you understand what is acceptable for you to receive or make in the way of gifts and hospitality, please consult the General Manager. Any charitable gift, whether made by a third party or to be made by us, needs the approval of Company Director.

Requests to make or receive payments other than those which relate to the normal course of our business must always be treated with suspicion. Consult with the General Manager about any situations or offers of payments etc. which have caused you or raise any suspicion.

Usually it will not be difficult to tell when something does not seem right. Usually it is very obvious, because what is occurring or what you are being asked to do is something which does not normally occur in your work for us. Equally, it may seem unreasonable or unethical to you as a reasonable person.

Raising concerns

We wish to encourage you to raise any concerns or suspicions you may have as soon as you have them. Even if you are not sure whether:

  • What has occurred; or

  • A payment; or

  • The actions of another employee; or

  • An action of someone who provides goods or services to us

amounts to bribery.

We urge you to raise your concerns with the General Manager. The Board of Directors wish to encourage the reporting of your concerns and suspicions and will wish it be known that if you do so you will not be subject to any disciplinary action or unfavourable treatment (or any threats relating to these). If you consider that you have been subject to such action or treatment, please use our grievance procedure.

This policy is reviewed on an annual basis and is freely available to our customers, suppliers, employees and the general public.

Peter Rowley
Company Director
06 March 2017

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