Anti-Bribery & Corruption Policy

Our Anti-Bribery and Corruption (ABC) Policy sets out the expectations for our people, and those working on our behalf, to prevent bribery and corruption. Awareness and compliance with the Policy is mandatory for all our employees and contractors. It is also mandatory for our majority-owned subsidiaries and any joint ventures that we control.

The ABC Standard and any related procedures are subject to oversight and ongoing monitoring by our leadership team.

Key Prohibitions and Requirements

Our ABC Standard sets out the prohibitions and requirements which must be adhered to. The key areas are:

It is expressly prohibited to engage in bribery either directly or via a third party. Bribery is defined as: offering, promising, or giving, requesting, seeking, or accepting anything of value, or any other advantage to improperly influence a business decision or any other act, inaction, or decision by any person in any country.
It is expressly prohibited to bribe a Public Official which is defined as: offering, promising, or giving anything of value, or other advantage to influence a Public Official in their role or in order to win or retain business or any other business advantage.
Facilitation payments are prohibited (unless there is a genuine risk to life or wellbeing).
Political donations are prohibited.

Gifts and Hospitality (‘G&H’)

All G&H must be given or received in line with our G&H Policy which is designed to address both bribery and independence risks and regulatory requirements.
G&H must be proportionate, reasonable and only offered as part of building or maintaining good relationships. It must not create an expectation of reciprocity.
G&H must never be offered, given, or received, where it could influence a business decision or in circumstances where it would threaten IM Power's independence, integrity or objectivity in any way.
It is prohibited to offer or give any gifts to a Public Official.
During a commercial negotiation with a client or supplier, G&H must not be offered, given or accepted by (a) the IM Power team who are involved in that negotiation to/from the client or supplier, or (b) any other IM Power employee who is aware of those commercial negotiations. It is, however, acceptable to provide/receive hospitality and refreshments as a standard business courtesy.

Charitable Donations

It is prohibited to provide a donation or sponsorship where that would influence, or could be perceived as influencing a business decision by the person or organization receiving it.
The donation or sponsorship must be reasonable and proportionate, and only given to support the aims of the charity which should align with our purpose and values.
It is also prohibited to provide donations or sponsorships where they coincide with a bidding process or contract renewal negotiations.
In general, IM Power will only donate to Power For Prosperity Foundation - a UK registered charity that will make grants or direct allocations based on the discretion of their leadership team and with oversight from their independent board of Trustees.

Recruitment

It is prohibited to recruit someone into a role within IM Power where that would influence a business decision by a client or other relevant decision-maker.
Where a candidate for a IM Power role has a known personal connection to a client, or to the person proposing their onboarding, then additional scrutiny will be applied to ensure that any recruitment is appropriate and in compliance with our ABC Standard and the law.