Anti-bribery and business conduct

Bribery and improper payments

• REPONS does not offer, promise, give, request or accept any payment or advantage intended to improperly influence a procurement decision.
• No facilitation payments. If a process is blocked, it is escalated or documented — not paid around.
• No kickback, rebate or private commission to an individual at a buyer or supplier organisation.
• No political contribution made on behalf of a buyer or to win business.

Gifts and hospitality

• Modest, transparent business hospitality only, appropriate to a commercial meeting.
• Nothing given during an active tender or bid evaluation.
• Nothing given in cash or cash equivalent.
• Anything offered to REPONS that exceeds a normal courtesy is declined.

Conflicts of interest

Where a REPONS person has any personal or financial interest in a supplier under consideration, that interest is disclosed and the person is removed from the selection decision. Suppliers are selected on technical conformity, commercial terms, delivery capability and recorded performance.

Agents and intermediaries

REPONS does not use an agent, consultant or introducer to do anything REPONS could not do itself under these principles. Any commission arrangement is contractual, documented and disclosed to the counterparty it concerns.

Accurate records

• Every quotation, order, cost and payment is recorded in the REPONS system against its transaction.
• No off-book account, false invoice or misdescribed payment.
• Supplier payments are made to the bank account of the contracting legal entity, verified independently of the email requesting it.

Reporting

A buyer, supplier or employee who suspects a breach of these principles should report it in writing to the procurement desk. Reports are taken seriously and a person who reports a genuine concern in good faith will not be penalised for it.