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.

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:

Whistle Blowing

Whistleblowing is the act of reporting wrongdoing which is in the ‘public interest’, which means if it affects others, e.g the general public.  

Humans can raise their concern at any time, in complete confidence in the first instance to the CEO.  If you are not satisfied with the explanation or reason given to you, you should raise the matter with the appropriate official organisation or regulatory body.  Alternatively, if you do not report your concerns to a Director, you should take them directly to the appropriate organisation or regulatory body.

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

Human Made will not treat you unfairly or you will not lose your job if you ‘blow the whistle’ and make a ‘qualifying disclosure’ about Human Made.   This means a disclosure of information that you genuinely and reasonably believe is in the public interest and shows that the company has committed a “relevant failure” by:

  1. Committing a criminal offence, e.g. fraud
  2. Breaking the law, e.g. not having the correct insurance
  3. A miscarriage of justice
  4. Endangering the health and safety of an individual
  5. Environmental damage; or
  6. Concealing any information relating to the above

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.

Made by Humans