1 Based on definitions in Sections 1 & 2 Bribery Act 2010 FINANCIAL CRIME POLICY This policy provides the necessary arrangements to reduce Fraud, Theft and Money Laundering to an absolute minimum. It also outlines the procedures designed to prevent persons associated with TG Holdcroft Holdings Ltd and its associated companies (“the Company”) from undertaking bribery. References in this policy to “Bribery” mean acts of bribery as defined or further described in Sections 1 to 5 of the Bribery Act 2010. Other expressions used which are given a meaning in that Act bear the same meanings. The Company will carry out risk assessments and provide the necessary controls and procedures to raise awareness of, identify, detect and prevent financial crime and establish a culture in which these procedures and team member behaviour work together effectively. The Company provides an appropriate channel for confidential feedback, commonly referred to as “whistleblowing”. The Company will pursue those found to have committed fraud and bribery and will take the necessary legal action to recover assets or otherwise recompense the Company and in appropriate cases instigate criminal proceedings by referring matters to the police, as well as instigating its disciplinary procedures. This policy applies to all team members and suppliers of goods and services to the Company and its Group. 1. INTRODUCTION 1.1 Fraud & Theft TG Holdcroft Holdings Ltd is a Family Owned multi-site motor retail group with a turnover (2017) in excess of £350 million and employing a workforce of approximately 550. Its activities are all based in the UK and primarily carried out in the North Staffordshire and South Cheshire regions. The nature and structure of our business places us at risk of loss due to fraud, theft and corruption (collectively referred to as “Fraud” in this policy) both from within and outside the Company. The Company is committed to preventing Fraud, or at the very least, reducing to a minimum the risk of loss through Fraud. This policy will be used by the Company to advise and guide our employees on this serious subject. “Fraud” is defined as:- Deception by persons internal or external to the Company, which is carried out to conceal the misappropriation of assets or otherwise for gain, whether by false representation, failure to disclose information or abuse of position. “Theft” is defined as:- The dishonest taking of property belonging to another with the intention of depriving the owner permanently of its possession 1.2 Bribery “Bribery” is defined as any of the following 1 :- offering, promising or giving a financial or other advantage as an inducement or reward for someone else to perform a relevant function or act improperly (i.e. bribing someone);
FINANCIAL CRIME POLICY
Jul 06, 2023
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