Anti-Bribery and Corruption

At Wise Auto, we commit ourselves to upholding high ethical standards. Our policies on anti-money laundering, sanctions, and antibribery and corruption aim to appropriately mitigate the risks identified by the company. 

We ensure that we appropriately mitigate money laundering risks identified by the FCA. This is achieved by establishing Board-approved minimum governing policies, principles, and standards and implementing appropriate controls to protect the Company, its employees, shareholders, and customers from money laundering. 

Policy Coverage:

This anti-bribery policy exists to outline the responsibilities of all employees and those working for Wise Auto in observing and upholding our zero-tolerance position on bribery and corruption. It also serves as a source of information and guidance for all employees, helping them recognize and address bribery and corruption issues while understanding their responsibilities. 

Policy Statement:

Wise Auto is dedicated to conducting business in an ethical and honest manner and to implementing and enforcing systems that prevent bribery. We maintain zero tolerance for bribery and corrupt activities, conducting all business dealings and relationships with professionalism, fairness, and integrity, regardless of the location. 

We commit to uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate, including the Bribery Act 2010 in the UK, both at home and abroad. 

Wise Auto acknowledges that bribery and corruption are punishable by up to ten years of imprisonment and a fine. Engaging in corrupt activities could result in an unlimited fine, exclusion from public contract tendering, and severe damage to our reputation. Therefore, we are firmly committed to preventing bribery and corruption within our business and take our legal responsibilities seriously. 

Scope of the Policy:

This anti-bribery policy applies to all employees (whether temporary, fixed term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other individuals associated with us (including third parties) or any of our subsidiaries or their employees, irrespective of their location (within or outside the UK). The policy also applies to Officers, Trustees, Board, and/or Committee members at any level. 

In the context of this policy, "third-party" refers to any individual or organization with which our company interacts and works. This includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, government and public bodies, politicians, and public parties, as well as their advisors, representatives, and officials. 

All arrangements made with a third party are subject to clear contractual terms, including specific provisions requiring compliance with minimum standards and procedures relating to anti-bribery and corruption. 

Definition of Bribery:

Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or an advantage to induce or influence an action or decision. 

A bribe refers to any inducement, reward, or item of value offered to another individual to gain commercial, contractual, regulatory, or personal advantage. 

Bribery is not limited to the act of offering a bribe; individuals on the receiving end of a bribe who accept it are also breaking the law. 

Bribery is illegal. Employees must not engage in any form of bribery, whether directly, passively, or through a third party (such as an agent or distributor). They must not bribe foreign public officials anywhere in the world, nor accept bribes in any degree. If uncertain about whether something constitutes a bribe, gift, or act of hospitality, employees must seek advice from the company's compliance manager. 

Acceptable and Unacceptable Conduct:

This section of the policy covers four areas:

1. Gifts and hospitality. 

2. Facilitation payments. 

3. Political contributions. 

4. Charitable contributions. 

Gifts and Hospitality:

Wise Auto accepts normal and appropriate gestures of hospitality and goodwill (whether given to or received from third parties) as long as they meet the following requirements: 

  • They are not given with the intention of influencing the party to whom they are being given to obtain or reward the retention of a business or business advantage or as an explicit or implicit exchange for favours or benefits. 
  • They are not given with the suggestion that a return favour is expected. 
  • They comply with local law. 
  • They are given in the name of the company, not in an individual's name. 
  • They do not include cash or a cash equivalent (e.g. a voucher or gift certificate). 
  • They are appropriate for the circumstances (e.g., giving small gifts around Christmas or as a small thank-you for helping with a large project's completion). 
  • They are of an appropriate type and value and given at an appropriate time, considering the reason for the gift. 
  • They are given/received openly, not secretly. 
  • They are not selectively given to a key, influential person, clearly with the intention of directly influencing them. 
  • They do not exceed a certain excessive value, as pre-determined by the company's compliance manager (usually in excess of £100). 
  • They are not offered to or accepted by a government official or representative or politician or political party without the prior approval of the company's compliance manager. 

In cases where declining the offer of a gift may be inappropriate (e.g., when meeting with an individual of a certain religion/culture who may take offense), the gift may be accepted as long as it is declared to the compliance manager, who will assess the circumstances. 

Wise Auto acknowledges that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, and thus definitions of what is acceptable and unacceptable may differ for each. As a good practice, gifts given and received should always be disclosed to the compliance manager, and gifts from suppliers should always be disclosed. 

Employees must consider the intention behind a gift being given/received, and when uncertain, they should seek advice from the compliance manager. 

Facilitation Payments and Kickbacks:

Wise Auto strictly prohibits the acceptance or making of any form of facilitation payments. We recognize that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. Similarly, kickbacks, which are typically made in exchange for a business favor or advantage, are not allowed. 

Wise Auto acknowledges that despite our strict policy, employees may face situations where avoiding a facilitation payment or kickback may put their personal security or their family's security at risk. In such circumstances, employees must take the following steps: 

  • Keep any payment to a minimum. 
  • Request a receipt detailing the amount and reason for the payment. 
  • Create a record concerning the payment. 
  • Report the incident to their line manager. 

Political Contributions:

Wise Auto does not make any donations, whether in cash, kind, or by any other means, to support any political parties or candidates, as this may be perceived as an attempt to gain an improper business advantage. 

Charitable Contributions:

Wise Auto accepts and encourages donations to charities, whether through services, knowledge, time, or direct financial contributions (cash or otherwise), and commits to disclosing all charitable contributions it makes. 

Employees must ensure that charitable contributions are not used to facilitate or conceal acts of bribery. All charitable donations made must be legal and ethical under local laws and practices, and donations must not be offered or made without the approval of the compliance manager. 

Employee Responsibilities:

As an employee of Wise Auto, you must read, understand, and comply with the information contained within this policy and with any training or other anti-bribery and corruption information provided. 

All employees and individuals under our control are equally responsible for preventing, detecting, and reporting bribery and other forms of corruption. They must avoid any activities that could lead to or imply a breach of this anti-bribery policy. 

If an employee has reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future, breaching this policy, they must notify the compliance manager. 

Breaching this policy may result in disciplinary action, and employees may face dismissal for gross misconduct. Wise Auto reserves the right to terminate a contractual relationship with an employee if they breach this anti-bribery policy. 

Addressing Concerns:

This section of the policy covers three areas: 

A. How to raise a concern

B. What to do if you are a victim of bribery or corruption 

C. Protection

A. How to raise a concern:

If you suspect that bribery or corrupt activities are occurring in relation to Wise Auto, you are encouraged to raise your concerns at the earliest possible stage. If uncertain about whether a certain action or behavior may be considered bribery or corruption, you should speak to your line manager, the compliance manager, the director, or the Head of Governance and Legal. 

Wise Auto will familiarize all employees with its whistleblowing procedures, allowing them to voice their concerns swiftly and confidentially. 

B. What to do if you are a victim of bribery or corruption:

You must inform your compliance manager as soon as possible if: 

  • You are offered a bribe by anyone. 
  • You are asked to make a bribe. 
  • You suspect that you may be bribed or asked to make a bribe in the near future. 
  • You have reason to believe that you are a victim of another corrupt activity. 

C. Protection:

Wise Auto understands that individuals who refuse to accept or offer a bribe or report concerns relating to potential acts of bribery or corruption may worry about potential repercussions. As such, we will support anyone who raises concerns in good faith under this policy, even if the investigation finds that they were mistaken. 

We ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential acts of bribery or corruption. Detrimental treatment refers to dismissal, disciplinary action, threats, or unfavourable treatment related to the raised concern. 

If you believe you have been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, you should inform your line manager or the compliance manager immediately. 

Training and Communication:

Wise Auto will provide training on this policy as part of the induction process for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy and will be asked annually to formally accept that they will comply with this policy. 

Wise Auto's anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third parties at the outset of business relations and as appropriate after that. Relevant anti-bribery and corruption training will be provided to employees, where needed, to enhance their knowledge of how to comply with the Bribery Act. As a good practice, all businesses should provide their employees with anti-bribery training where there is a potential risk of facing bribery or corruption during work activities. 

Record Keeping:

Wise Auto will maintain detailed and accurate financial records and will have appropriate internal controls in place as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given, as gifts and acts of hospitality are subject to managerial review. 

Monitoring & Reviewing:

Wise Auto's compliance manager is responsible for monitoring the effectiveness of this policy and will review its implementation on a regular basis. They will assess its suitability, adequacy, and effectiveness. 

Internal control systems and procedures designed to prevent bribery and corruption will be subject to regular audits to ensure they are effective in practice. Any necessary improvements will be applied promptly. Employees are encouraged to offer feedback on this policy if they have any suggestions for improvement, which should be addressed to the compliance manager. 

This policy does not form part of an employee's contract of employment, and Wise Auto may amend it at any time to improve its effectiveness in combatting bribery and corruption.