Renishaw Anti-bribery policy
Renishaw has a zero tolerance approach to any form of bribery or corruption.
Our global anti-bribery programme is designed to ensure all employees comply with this approach and aligns with the six principles of the UK Bribery Act.
On 1st July 2011 the UK Bribery Act 2010 came into force and Renishaw has published its 'zero-tolerance' approach to any form of bribery or corruption. A committee set up in 2011 analysed the risks of bribery within the Group and following its recommendations, the Board approved the adoption and implementation of the Renishaw Group Anti-Bribery Policy ("the Policy"). Our global anti-bribery programme is designed to ensure all employees comply with the zero-tolerance approach and aligns with the six principles of the UK Bribery Act:
The programme is managed centrally to ensure a consistent approach, but also allows local markets to tailor specific elements.
Renishaw's senior management take an active role in implementing the Policy. The Executive Directors receive updates on performance and progress.
The in-house legal department has worked with senior management both in the UK and other countries in which the Group operates to identify the higher risk areas and is working in collaboration with management through a compliance programme to mitigate risk. Each region is required to put in place anti-bribery procedures that are appropriate to their operating environment.
Our risk-based approach extends to suppliers and business partners/associated persons. The programme includes providing the Policy to agents and other representatives of the Group and due diligence procedures when appointing new agents and representatives.
Communication (including training)
The Policy has been issued to all staff (including new staff as part of their induction process) and a dedicated intranet page has been set up with related key documentation. Staff who may encounter bribery and corruption during the course of their duties have been identified and are undertaking an online training module, along with other training. Renishaw's employees have a duty to report any suspected breaches of the Policy.
Monitoring and review
We regularly monitor and review compliance with anti-bribery requirements through our internal controls processes and regular reports to the Audit committee and the Board, and we also address any new or emerging risks.
Full details of our Anti-Bribery Policy can be found in the document below.
Summary of anti-bribery programme to date 18/2/2015
- An all staff anti-bribery portal has been set up with dedicated documentation for staff across the Group including our policy, template notification letters, diligence questionnaires, red flag situation examples etc;
- One to one presentations on the policy (as well as risk assessments) were also carried out across the business to key subsidiary and divisional heads as well as plc Board training. Risk assessments are currently being updated on a risk based approach and certain higher risk subsidiaries are being contacted;
- We have also been through an exercise of updating our intermediary contracts across the group and have written to appropriate intermediaries/suppliers notifying them of our policy and expectations in this area;
- An E-Learning training module on the policy was designed/translated as required and has been completed by a large cross section of appropriate global staff;
- We are regularly monitoring compliance and our internal audit function has included within its procedures specific checks/declarations as part of its subsidiary audit visits;
- A new joiner process is also managed globally by UK HR and Group Legal so that appropriate new staff receive anti-bribery training;
- A new supplier portal was implemented which seeks compliance with our policy when suppliers are being selected.