Anti-Bribery and Corruption Policy

1. Introduction

South Wales Medical Services (SWMS) is committed to conducting its business with the highest standards of integrity, transparency, and ethical behavior. This Anti-Bribery and Corruption Policy outlines our zero-tolerance approach to bribery and corruption and provides guidance to all employees, contractors, agents, and business partners on how to identify and prevent such activities.

2. Policy Statement

SWMS strictly prohibits any form of bribery or corruption in all of its business dealings. This policy applies to all employees, contractors, agents, consultants, business partners, and anyone else acting on behalf of SWMS.

3. Definitions

  • Bribery: The offering, giving, receiving, or soliciting of anything of value, such as gifts, money, favors, or services, with the intent to influence the actions or decisions of an individual in a position of trust.
  • Corruption: The abuse of entrusted power for personal gain, often involving dishonest or unethical behavior.
  • Facilitation Payment: A small payment made to expedite routine actions that a person is already obligated to perform.

4. Compliance

4.1. All employees, contractors, agents, and business partners are expected to adhere to this policy and must not engage in any bribery or corruption-related activities.

4.2. SWMS will provide adequate training and resources to ensure that all individuals associated with the company understand their responsibilities in preventing bribery and corruption.

4.3. Failure to comply with this policy may result in disciplinary action, up to and including termination of employment or contract, and possible legal action.

5. Prohibited Activities

5.1. No employee or representative of SWMS shall offer, give, receive, or solicit bribes, kickbacks, or facilitation payments to or from any individual, organization, or entity, whether in the public or private sector.

5.2. SWMS personnel shall not engage in any activity that may lead to conflicts of interest, which could compromise their impartiality or judgment in business decisions.

5.3. Acceptance of gifts, hospitality, or other benefits from business partners must be transparent, modest, and in compliance with SWMS’s Gifts and Hospitality Policy.

6. Reporting

6.1. Any individual who suspects or becomes aware of a potential breach of this policy is obligated to report it immediately to their supervisor, manager, or the designated compliance officer.

6.2. SWMS will investigate all reports of potential bribery and corruption thoroughly and confidentially. No retaliation will be taken against those who report in good faith.

7. Record Keeping

7.1. SWMS will maintain accurate records of all transactions, contracts, and interactions involving business partners, consultants, and suppliers. These records will be retained in accordance with legal requirements.

8. Communication and Training

8.1. SWMS will communicate this policy to all employees, contractors, agents, and business partners and provide training on anti-bribery and corruption measures.

9. Monitoring and Review

9.1. SWMS will regularly review and update this policy to ensure its effectiveness and relevance.

10. Conclusion

SWMS is committed to maintaining the highest ethical standards and fostering a culture of integrity, honesty, and transparency. This policy reflects our dedication to preventing bribery and corruption in all aspects of our operations. Every individual associated with SWMS is responsible for upholding and implementing this policy.


Simon Garratt
Managing director
18th August 2023