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Anti-bribery Policy
2024

Introduction
Pure Klass Cleaning is committed to conducting all aspects of our business honestly and with integrity. We uphold all laws relevant to countering bribery and corruption and expect all staff and contractors to maintain the highest standards of conduct.

Policy Statement
We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally and fairly in all our business dealings and relationships.

Scope
This policy applies to all individuals working at all levels within Pure Klass Cleaning, including senior managers, officers, directors, employees, consultants, contractors, trainees, seconded staff, volunteers, interns, agents, or any other person associated with us.

What is Bribery?
Bribery involves the offering, giving, receiving, or soliciting of any item of value as a means of influencing the actions of an individual holding a public or legal duty.

Prohibitions
We prohibit:

The offering, promising, giving, accepting, or seeking of a bribe in any form.
The use of other routes or channels to provide improper benefits to clients, agents, contractors, suppliers, or employees of any such party or government officials.

 

Gifts and Hospitality
We do not allow the exchange of gifts or hospitality that may be deemed to influence a business decision-making process.

Compliance
All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. We provide necessary training to ensure they understand their responsibilities.

 

Reporting Violations
Employees are encouraged to report any concerns or suspicions of bribery or corruption to their immediate supervisor or the compliance officer. See below for further details on our process.

Disciplinary Action
Failure to comply with this policy will result in disciplinary action, which could result in dismissal for gross misconduct. We reserve the right to terminate our contractual relationship with suppliers and contractors if they breach this policy.

Monitoring and Review
The board of directors will monitor the effectiveness and review the implementation of this policy, considering its suitability, adequacy, and effectiveness.

Process for employees

If you suspect bribery or corruption anywhere within Pure Klass Cleaning, you should follow this guidance. 


Action by employees 
Write down your concerns immediately. Make a note of all relevant details, such as what was said in person, on the phone, in any conversation or via any medium such as text messages.  Note all other relevant conversations, the date, the time and the names of anyone involved. 


Report the matter immediately to your line manager or to Moses Opone the Managing Director. Give them any notes you have made or any evidence you have gathered. Don't tell anyone else about your suspicions. 


Action by managers 
Listen to the concerns of your staff and treat every report you receive seriously and sensitively. Do not ridicule suspicions raised by staff. 


Make sure that all staff concerns are given a fair hearing. You should also reassure staff that they will not suffer because they have told you of their suspicions. 


Get as much information as possible from the member of staff, including any notes and any evidence they have that may support the allegation. Do not interfere with any evidence and make sure it is kept in a safe place. 


Assess whether the suspicions are justified before you take the matter further. Be objective when evaluating the issue. Consider the facts as they appear based on the information you have to hand. If in doubt, report your suspicions anyway. 


Report the matter immediately to Moses Opone the Managing Director. Do not convey your suspicions to anyone other than those with the proper authority. 


Everyone 
Do not try to carry out an investigation yourself as this may damage any Internal Audit or criminal enquiry. 
Help any personnel authorised by Moses Opone in any investigations. 

This policy is communicated to all employees and organisations with which we work.

Signed

Moses Opone

Managing Director

March 2024

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