Anti-Bribery &
Corruption Policy.
Neil Fogarty Research LLP (“the Firm”) is committed to conducting all of its business fairly, honestly and transparently. The Firm has zero tolerance for bribery and corruption in any form.
This commitment applies to:
- Partners and employees of the Firm.
- Contractors, consultants, temporary staff and interns.
- Agents, intermediaries, joint‑venture partners and any other third parties acting on the Firm’s behalf.
The Firm complies with all applicable anti‑bribery and corruption laws, including the UK Bribery Act 2010, and acts in the spirit of the UN Global Compact and related international standards.
1. Prohibited conduct
No one acting for or on behalf of the Firm may, directly or indirectly:
- Offer, promise, give, request or accept a bribe, kickback or any improper advantage, whether in cash or in kind.
- Make facilitation payments (small, unofficial payments to secure or speed up routine actions), regardless of local practice.
- Offer or accept gifts, hospitality or expenses where they could improperly influence, or reasonably be seen to influence, a decision or create a conflict of interest.
- Use third parties to do anything that the Firm itself is prohibited from doing.
“Bribe” means any financial or other advantage offered, given, requested or received with the intention of inducing or rewarding the improper performance of a function or activity, or in expectation of a favourable decision.
2. Risk‑based controls
The Firm operates a risk‑based anti‑bribery and corruption framework, which includes:
- Periodic assessment of bribery and corruption risks relating to its services, sectors and geographies.
- Due‑diligence on higher‑risk third parties (such as intermediaries, local partners and key suppliers).
- Clear rules on gifts and hospitality, including approval thresholds and recording requirements.
- Contractual clauses requiring third parties to comply with equivalent anti‑bribery and corruption standards.
The Firm reserves the right not to enter into, or to terminate, relationships with organisations or individuals that do not demonstrate a comparable commitment to integrity.
3. Responsibilities and training
Overall responsibility for this Policy rests with the Firm’s partners. Day‑to‑day oversight is delegated to the Compliance Officer, who is responsible for:
- Maintaining and updating the Firm’s anti‑bribery and corruption procedures.
- Providing appropriate training and guidance to relevant staff and partners.
- Monitoring compliance and reporting significant issues to the partners.
All partners, employees and relevant third parties are expected to complete any required training and to familiarise themselves with the detailed procedures that support this Policy.
4. Speaking up and non‑retaliation
Anyone working for or with the Firm is encouraged – and expected – to raise concerns about suspected bribery or corruption at the earliest opportunity. Concerns can be raised with:
- The Compliance Officer; or
- Any partner of the Firm.
The Firm will treat all reports seriously, investigate them as appropriate, and will not tolerate retaliation against anyone who raises a concern in good faith, even if it is not ultimately substantiated.
5. Consequences of breach
Breaches of this Policy may constitute serious misconduct and will be dealt with under the Firm’s disciplinary procedures. They may result in:
- Disciplinary action up to and including dismissal for employees.
- Termination of contracts or relationships with third parties.
- Reporting to law‑enforcement or regulatory authorities where required.
Bribery and corruption are criminal offences and may result in fines and imprisonment for individuals, and significant penalties and reputational damage for the Firm.
6. Further information
Questions about this Policy or its application should be directed to the Compliance Officer at Neil Fogarty Research LLP.
This Policy is reviewed regularly to ensure it remains effective and aligned with legal requirements and the Firm’s wider ethical commitments.