AND THIS IS THEIR HYPOCRITICAL POLICY STATEMENT
Group Anti-Bribery Policy
GROUP ANTI-BRIBERY POLICY SUMMARY FOR THIRD PARTY SUPPLIERS
Lloyds Banking Group has a moral and ethical duty to act with the highest standards of integrity and honesty in all it does. This Policy builds on the Group’s corporate responsibility to its customers, shareholders and colleagues to deter, detect and disrupt those who would seek to use the Group to facilitate any form of financial crime.
Lloyds Banking Group has no appetite for breaching bribery and corruption legislation and/or regulation. This includes activities conducted by an external party supplying services for or on behalf of the Group, or acting on the Group’s behalf (the “Supplier”).
In the UK these requirements are included in (amongst others):
- Bribery Act 2010, in particular sections 1, 2 and 7 which enable the prosecution of individuals and commercial organisations;
- Bribery Act 2010 Guidance about procedures which relevant commercial organisations can put into place to prevent persons associated with them from bribing (section 9 of the Bribery Act 2010);
- Proceeds of Crime Act (POCA) 2002;
- Financial Conduct Authority (FCA) Handbook’s Principles for Business, inparticular, principles 1, 2, 3 and 8;
- FCA Financial Crime – a Guide for Firms (in particular Part 1 – sections 2 & 6,Part 2 – sections 9 & 13); and
- US Foreign Corrupt Practices Act 1977 (and any other jurisdictionallegislation that has extra-territorial application).
In jurisdictions where the local legislative and regulatory requirements exceed the requirements set out in this document, the Supplier must comply with such higher standards.
The primary aim of anti-bribery risk management is to ensure that payments, offers, promises of a bribe (making a bribe) or receipt, requests or acceptance of a bribe (being bribed) by an individual or associated party does not occur.
The purpose of this Policy is to:-
- ensure compliance with anti-bribery legislation both in the UK and in the other jurisdictions in which the Group operates; and
- provide a consistent, proportionate and effective approach to anti-bribery through a framework of core requirements and a set of minimum standards.Definition
For the purposes of this Policy bribery is defined as ‘an offer or receipt of any gift, fee, reward or other advantage to or from any person as an inducement to do something in the conduct of the Group’s business, which is dishonest, illegal or a breach of trust’.