Your Homes Newcastle

Group Statement on Anti-Bribery and Corruption

This is a group policy statement by Your Homes Newcastle Limited in respect of the organisation’s commitment to meet its responsibilities under the provisions of the Bribery Act 2010 (‘the Act’), which came into force on 1 July 2011.

We are committed to carrying out our business transparently and fairly and operate a zero tolerance policy towards bribery by our Board members, employees, contractors, agents and other associated persons.  Incidents of bribery could lead to our reputation being damaged and also lead to deterioration in our relationship with tenants, customers, business colleagues and other stakeholders.

We are committed to working only with other organisations and/or individuals who are also committed to doing business without bribery.  Any organisation and/or individual who wish to work with us must demonstrate such commitment to conducting their business without corruption and bribery.

The YHN Group Board has approved an Anti-Bribery Policy (‘the Policy’) which complements other policies and procedures to ensure that we are best placed to achieve and maintain high standards of corporate and individual responsibility. 

We will comply with the Act by following the principles of:

Proportionality	Anti-bribery policies and procedures are proportionate to our activities, the sector in which we operate and the risks we face.
Top level commitment	We will establish a clear culture within the organisation in which bribery is unacceptable.
Risk Assessment	We will understand the bribery risks we face by carrying out regular and comprehensive risk assessments.
Due Diligence	We will make sure our partners and contractors also have common anti-bribery agreements in place.
Communication	We will take measures so that all employees, board members and business partners know the procedures to follow in situations which may be sensitive to bribery and that our anti-bribery policies are embedded in our culture.
Monitoring and Review	We will monitor and review procedures designed to manage the risks of internal and external bribery and corruption.

The Policy applies to all Group Board members, committee members and employees.  We will also apply the provisions of the Policy, as they relate, to all of its commercial and non-commercial arrangements and to individuals and organisations which have a relationship with us including contractors, agents and consultants.  All of these parties are required to familiarise themselves with the Policy and the processes and procedures contained within it, and to make sure they follow it at all times throughout their relationship with us.

We also have other controls in place to prevent bribery, corruption and related in appropriate conduct.  These include:

• Employee terms and conditions including contracts of employment;
• Employees Code of Conduct;
• Board member service agreements;
• Board member Code of Conduct;
• Group Governance Framework and Financial Regulations;
• Corporate Procurement Strategy; and
• Whistleblowing Policy; and

We take our stance on bribery extremely seriously.  Apart from the benefits to us that all we deal with are operating on a fair and level playing field when transacting business, we are also mindful of the penalties which can apply in the event of a proven case of bribery.

Prosecution under the Act could lead to penalties for our senior officers with whose ‘consent or connivance’ bribery was committed.  Individuals can be found guilty of bribery and, in the most serious cases, be liable on conviction to imprisonment for up to 10 years, to a fine, or to both.

In addition, individuals could be liable for bribing, receiving a bribe or bribing a foreign public official.  Again, such individuals could be liable on conviction to imprisonment for up to 10 years, to a fine or to both.

The YHN Group Board has overall responsibility for ensuring that all policies and procedures are kept up to date.  It has delegated to the Company Secretary the specific responsibility for maintaining general awareness of and compliance with the Policy and the Bribery Act.

Any person who has concerns about acts of bribery or what appears to be a suspicious transaction, payment or benefit given to or received by anyone whilst acting for us should contact the Company Secretary or in writing to the address shown below in confidence, for investigation under the terms of the Policy and our Whistleblowing Policy.

If you have a general question or a requirement for further information on the Policy or any of the issues covered within it, please contact the Company Secretary.

 

Tony Gates

Chair of YHN Group Board                    

20 September 2022                                   

 

Tina Drury

Group Managing Director

20 September 2022

 

 

Your Homes Newcastle Limited.  Registered in England and Wales.  Registration Number 5076256.

Contact address: YHN House, Benton Park Road, Newcastle upon Tyne, NE7 7LX