No offering of bribes
Money, benefits or advantages must not be offered to secure improper treatment, business or influence.
Corporate Policy
Anti-Bribery and Corruption Policy.
Black Fleet London is committed to conducting business honestly, transparently and without bribery, corruption, improper payments or inappropriate influence.
This public policy summarises Black Fleet London’s anti-bribery controls and expectations. Detailed reporting routes, risk records and investigation procedures are maintained separately where appropriate.
Purpose
Preventing improper influence across our commercial relationships.
The purpose of this policy is to establish Black Fleet London’s prohibition of bribery and corruption and to explain the standards expected when representing, supplying or conducting business with the company.
Anti-bribery considerations form part of procurement, supplier onboarding, account management, payment controls, hospitality, partnerships and other commercial decision-making.
Scope of this policy
- Directors, employees, contractors and representatives
- Licensed private hire operators supporting service delivery
- Chauffeurs, vehicle suppliers and other operational providers
- Technology, professional and administrative suppliers
- Corporate clients, business partners and intermediaries
- Gifts, hospitality, discounts, commissions and promotional activity
- Public-sector, international and private-sector relationships
Policy Statement
Zero tolerance for bribery, corruption and improper influence.
No person acting for or on behalf of Black Fleet London may offer, promise, give, request, agree to receive or accept an improper financial or other advantage.
No accepting of bribes
Individuals must not request or accept benefits in exchange for improper decisions or preferential treatment.
No indirect bribery
A third party, intermediary, supplier or representative must not be used to perform an act prohibited by this policy.
No facilitation payments
Unofficial payments intended to accelerate or secure routine action are prohibited, except where personal safety is genuinely threatened.
No retaliation
No person should suffer retaliation for refusing a bribe or raising a genuine concern in good faith.
Transparent records
Payments, benefits, discounts and commercial arrangements must be recorded accurately and not concealed through false descriptions.
What Bribery May Involve
Improper advantage can take many forms.
Bribery is not limited to envelopes of cash. The circumstances, intention, recipient and expected outcome must all be considered.
Cash and payments
Direct payments, concealed fees, kickbacks, rebates or personal transfers.
Gifts and hospitality
Excessive or strategically timed gifts, travel, accommodation, entertainment or meals.
Preferential treatment
Improper allocation, supplier approval, pricing, payment or access to confidential opportunities.
Employment and contracts
Jobs, contracts or commercial opportunities offered to improperly influence a decision.
Charitable contributions
Donations used as a route to secure improper commercial or official influence.
Political contributions
Political support connected to an expected business or regulatory advantage.
Discounts and credits
Personal discounts, credits or refunds not connected to a legitimate commercial purpose.
Favours and services
Free journeys, personal services or benefits supplied in exchange for improper influence.
Prevention Framework
Six principles supporting proportionate bribery-prevention procedures.
Controls should reflect the company’s size, activities, relationships and bribery risks.
Leadership should communicate that bribery is unacceptable and support ethical commercial conduct.
Relevant geographical, transactional, supplier and partnership risks should be considered.
Proportionate checks should be applied to individuals and organisations performing services for the company.
Relevant expectations and reporting routes should be understood by those exposed to bribery risk.
Procedures should be reviewed against incidents, business change and emerging risk.
Gifts and Hospitality
Reasonable business hospitality must never become improper influence.
Genuine and proportionate hospitality may support legitimate business relationships. It must not be offered or accepted to obtain an improper advantage, influence a live decision or create an undisclosed obligation.
Purpose
There must be a genuine and legitimate business reason.
Value
The value and frequency must be reasonable and proportionate.
Timing
Particular caution is required during tenders or commercial decisions.
Transparency
The arrangement should withstand internal and external scrutiny.
Decision Test
Questions to consider before offering or accepting a benefit.
01
Legitimate?
Is there a genuine business purpose unrelated to improper influence?
02
Proportionate?
Is the value reasonable considering the relationship and circumstances?
03
Independent?
Could the recipient still make an impartial decision?
04
Transparent?
Could the benefit be openly recorded and explained?
05
Appropriate?
Would a reasonable third party consider it proper?
When uncertain, do not proceed without approval
A gift, benefit or hospitality arrangement should be declined or referred for review where its purpose, value, timing or recipient creates concern.
Facilitation Payments
Unofficial payments for routine action are prohibited.
Black Fleet London prohibits unofficial payments intended to secure or accelerate routine government, regulatory, administrative or commercial activity.
A demand should be refused and reported unless the individual reasonably believes that refusal would create an immediate threat to personal safety.
If a payment is demanded
- Ask for the legal or official basis of the payment
- Request an official invoice or receipt
- Decline unofficial payment where it is safe to do so
- Do not conceal or falsely describe any payment made
- Report the demand promptly
- Record any payment made under a genuine safety threat
Conflicts of Interest
Personal interests must not improperly influence business decisions.
A conflict may arise where personal, family, financial or other relationships could affect—or appear to affect—an individual’s independence and judgement.
A conflict is not necessarily wrongdoing, but it must be disclosed and managed transparently.
Conflicts requiring disclosure may include
- Personal or family interests in a supplier
- Undisclosed commissions or referral payments
- Secondary employment affecting impartiality
- Personal relationships with decision-makers
- Financial interests in competing businesses
- Benefits connected to supplier selection or allocation
Suppliers and Operating Partners
Third parties expected to conduct business without bribery or corruption.
Black Fleet London may be exposed to liability and reputational harm through individuals and organisations performing services on its behalf. Appropriate third-party controls are therefore important.
Identity and standing
The organisation or individual performing the service should be identifiable and appropriately established.
Commercial rationale
Services, commissions and payments should have a genuine and documented commercial purpose.
Proportionate payment
Compensation should be reasonable for the service and paid through transparent channels.
Clear expectations
Suppliers should understand the prohibition of bribery, improper payments and hidden benefits.
No hidden intermediaries
Unauthorised subcontracting or unidentified intermediaries should not be used to conceal payments or influence.
Reporting and cooperation
Suppliers should report credible concerns and cooperate with proportionate enquiries.
Financial Records
Payments recorded accurately and transparently
Invoices, commissions, discounts, expenses, gifts and other commercial transactions should be described accurately and supported by appropriate evidence.
False, misleading or incomplete records must not be created to conceal an improper payment or benefit.
Cash and Refund Controls
Unusual payment arrangements require scrutiny
Requests for payment to unrelated individuals, unexplained cash transactions, excessive commissions or refunds to different accounts should be reviewed before processing.
Commercial urgency must not override reasonable verification.
Raising a Concern
Suspected bribery should be reported without unnecessary delay.
Employees, contractors, operators, chauffeurs and suppliers should report requests, offers or conduct that may involve bribery, corruption, kickbacks or improper influence.
Individuals should not attempt to conceal a concern or conduct an unauthorised investigation themselves.
Reportable concerns may include
- Requests for cash, gifts or personal benefits
- Unexplained commissions or referral fees
- Pressure to use an unidentified intermediary
- False invoices or misleading expense descriptions
- Improper incentives connected to tenders or contracts
- Retaliation against someone refusing an improper request
- Conflicts of interest that have not been disclosed
Responding to Concerns
Concerns assessed fairly, confidentially and proportionately.
Protect
Consider confidentiality, evidence preservation and any immediate risk.
Assess
Review the credibility, seriousness and commercial context of the concern.
Investigate or escalate
Obtain appropriate internal, professional or regulatory support where needed.
Act and improve
Apply corrective, contractual or disciplinary action and improve controls.
Protection for genuine reporting
Black Fleet London does not tolerate retaliation against a person who refuses to participate in bribery or raises a genuine concern in good faith, even where the concern is not ultimately substantiated.
Roles and Responsibilities
Anti-bribery responsibility across leadership and service delivery.
01
Director
Demonstrates senior-level commitment, approves the policy and oversees significant risks and investigations.
02
Operations and finance
Apply payment, supplier, allocation and record-keeping controls and escalate unusual arrangements.
03
Operators and suppliers
Conduct business without bribery, maintain transparent records and report credible concerns.
04
All representatives
Refuse improper requests, disclose conflicts and seek guidance where circumstances are unclear.
Communication and Awareness
Expectations communicated according to role and risk
Relevant employees, contractors and suppliers should receive proportionate information concerning bribery risks, gifts, conflicts, financial controls and reporting routes.
Additional guidance may be issued for procurement, international activity, public-sector relationships or higher-risk transactions.
Monitoring and Review
Controls reviewed against business activity and emerging risk
Black Fleet London may review supplier onboarding, unusual payments, gifts and hospitality, conflicts, concerns raised and corrective actions.
This policy should be reviewed at least annually and following a significant concern, business change or relevant legal development.
Breach of policy
A breach may result in removal from an assignment, suspension of access, termination of a supplier or contracting relationship, disciplinary action or referral to an appropriate authority.
Related Governance
Ethical commercial conduct supported by connected policies.
Supplier Code of Conduct
Ethical, operational and transparency requirements for suppliers and operators.
Whistleblowing Policy
Protected reporting routes for serious wrongdoing and improper conduct.
Modern Slavery Statement
Human-rights, supply-chain and responsible working commitments.
Ethical Business and Due Diligence
Need further anti-bribery or supplier information?
Corporate clients and prospective partners may contact Black Fleet London regarding ethical-business controls, supplier onboarding, procurement requirements or proportionate supporting evidence.