Anti-bribery, whistleblowing, and corruption

Human Made is committed to applying the highest standard of ethical conduct and integrity in its business activities.  Every individual employed by Human Made as an employee or long-term contractor, and every individual acting on Human Made’s behalf is responsible for conducting company business honestly and professionally.

Employees and contractors  are encouraged to report any concerns to the CEO in the first instance, who will treat the matter with complete confidence, or alternatively to an appropriate organisation or regulatory body.

Whistleblowing

Human Made holds itself to the highest standards for conduct and security. We request that all employees, suppliers, clients, and other third parties who interact with Human Made report any failures to meet these standards, as outlined in this policy.

Whistleblowing

Whistleblowing is taking action to report wrongdoing that affects others. You are protected by law if you blow the whistle. We encourage anyone who works at or with Human Made to disclose any wrongdoing that they encounter. Human Made will not treat you unfairly nor will you lose your job if you make a qualifying disclosure about Human Made. A qualifying disclosure is information that you genuinely and reasonably believe is in the public interest and shows that the company has committed a “relevant failure” This includes:

  • Information security events, such as:
    • Phishing emails or telephone calls
    • Access violations
    • Breaches of Human Made’s confidentiality policy
    • Security vulnerabilities on Human Made’s website or our plugins
    • Security vulnerabilities on client websites 
    • Uncontrolled system changes
    • Staff misconduct relating to information security
    • Loss of laptop or mobile phone
    • Security weaknesses or data breaches at suppliers, partners or clients
  • Staff conduct issues, such as:
    • Committing a criminal offence, such as fraud
    • Breaking the law
    • A miscarriage of justice
    • Environmental damage
    • Endangering the health and safety of an individual or group of people
  • Concealing any information relating to the above

As a ‘whistleblower’ you can find local information in these places:

These acts can be in the past, present or future, so that, for example, a disclosure qualifies if it relates to environmental damage that has happened, is happening, or is likely to happen. Human Made will take concerns that you may raise relating to the above matters very seriously.

Bullying, harassment or any other detrimental treatment afforded to a Human who has made a qualifying disclosure is unacceptable and will not be tolerated. Anyone found to have acted in such a manner will be subject to disciplinary action by Human Made.

Disclosure

Issues should be disclosed to:

You may disclose issues anonymously by creating a new email account. You can follow this guide to learn how to send email anonymously.

Bribery and Corruption

Human Made is committed to carrying out business in a transparent and ethical way by helping to ensure that there is honest, open and fair competition in our sectors.   We believe that where there is a level playing field, Human Made can lead the market by delivering excellent services and products to its customers.

A bribe is a financial advantage or other reward that is offered to, given to, or received by an individual or company (whether directly or indirectly) to induce or influence that individual or company to perform public or corporate functions or duties improperly.

Human Made does not tolerate any form of bribery by, or of, its employees or any persons or companies acting for it or on its behalf and we are committed to implementing and enforcing effective systems to prevent, monitor and eliminate bribery.

Employees, contractors, and others acting for or on behalf of Human Made are strictly prohibited from making, soliciting or receiving any bribes or unauthorised payments. As part of its anti-bribery measures, Human Made is committed to engage only in transparent, proportionate, reasonable and bona fide hospitality and promotional expenditure. It’s important that gift purchases are signed off by the relevant Exec or Director. A record should be kept of gifts in excess of £50.

Guidelines

Please follow these guidelines when giving gifts:

  • Give gifts of nominal value.
  • Do not give gifts frequently to the same individual or group.
  • Do not exceed £50 for an individual gift.
  • Give gifts that are perishable, such as plants, or consumable, such as panettone, and that an entire office can share instead of just one individual.
  • Give gifts with a corporate logo that promote Human Made but do not have retail value.
  • Give something unique from your region.
  • Never give cash or cash equivalents, such as gift cards.
  • When giving a gift, do so publicly (e.g. in a Slack channel or group email)
  • Give gifts for official, rather than personal, use.
  • Make sure that any gift would comply with both local law and the internal policies at the official’s company.
  • Clear gifts through the exec.

Breach

A breach of this policy by an employee or contractor will be treated as grounds for disciplinary action, which may result in a finding of gross misconduct and immediate dismissal.   Humans and other individuals acting for Human Made should note that bribery is a criminal offence that may result in imprisonment and/or an unlimited fine for the individual and an unlimited fine for Human Made.

Human Made will not conduct business with suppliers, agents or representatives that do not support Human Made anti-bribery objectives.

Legislation

The following anti-bribery legislation applies: