1. Health & Safety Policy
2. Code of Conduct & Anti-bribery Policy
1. HEALTH & SAFETY POLICY
We take very seriously the health and safety of our own team, our contractors, clients, visitors and members of the public with whom any of us may come into contact.
Our HSE manager is responsible for health and safety. Our senior management team will review this policy annually and will respond immediately to any legislative changes that may take place between reviews.
Our legal obligations
Critica Group Ltd recognises the legal obligations placed on it by the Health and Safety at Work Act 1974 and other legislation relevant to our business. To this end, we will…
- Make our health and safety documentation and records freely available to all employees and available on request to contractors, visitors and members of the public and anyone else who may be affected by our operations
- Encourage employees to raise, as a positive duty, any health and safety issues they may have about how we operate.
Our responsibilities
We will ensure, as far as is reasonably practicable, the heath, safety, and welfare at work of all our employees and adhere to the measures contained in Health and Safety at Work Act 1974. To this end, we will…
- Commit to the additional requirements set out in the Management of Health and Safety at Work Regulations 1999 by…
- Completing compliant written risk assessment
- Recording arrangements for the planning, organisation, control, monitoring, and review of all workplace health and safety measures
- Employing where appropriate competent people to help us comply with our health and safety duties.
- Putting in place appropriate emergency procedures and ensuring all employees are made aware of these procedures
- Giving relevant health and safety information to staff and any others sharing the same workplace
- Providing relevant health and safety training
- Ensuring temporary workers have access to adequate health and safety information
- Protecting new and expectant mothers and young people from particular risks
- Delivering, as covered by Regulation 6, health surveillance for employees.
- Identify and ring fence adequate financial resources to invest in health and safety measures and staff training.
Our employees’ duties
Critica Group employees are expected to…
- Take reasonable care for the health and safety of themselves and others affected by their acts or omissions
- Cooperate with managers and others to enable them to fulfil their legal obligations
- Use equipment and substance in accordance with the health and safety training we deliver
- Report any serious or imminent danger
- Log shortcomings in our health and safety arrangements.
2. CODE OF CONDUCT & ANTI-BRIBERY POLICY
Overview
Critica Group’s ethos is to conduct all of our business in an ethical manner and with honesty, integrity, and fairness, and we take a zero-tolerance approach to bribery and corruption.
This policy applies to Critica staff, all contractors, and others working for the company on an ad hoc basis.
In this policy, ‘third party’ means any individual or organisation Critica staff come into contact with during the course of their work, including actual and potential clients, suppliers, agents, business contacts, and public bodies and anyone representing them.
Under the Bribery Act 2010 bribery and corruption are punishable by up to 10 years’ imprisonment, a fine, or both. If Critica Group Ltd were found to have taken part in corruption, or failed to prevent bribery, the company could face an unlimited fine, and be prevented from tendering for public contracts.
Any breach of this policy will be taken seriously, and may result in disciplinary action likely to amount to gross misconduct and to lead to dismissal.
Our managing director is responsible for this policy, and our senior management team will review it annually. They will also respond immediately to any legislative changes that may take place between reviews.
What constitutes bribery
The term ‘bribery’ has its usual everyday meaning, that is an inducement or reward offered, promised, or given in order to gain any commercial, contractual, regulatory, or personal advantage. Gifts, hospitality and entertainment can be bribes if intended to influence a decision.
The offence of bribing a foreign public official is committed as soon as the offer is made because it is made to gain a business advantage for us.
Gifts, hospitality, and entertainment
Normal and appropriate gifts, entertainment, and hospitality (given and received) to or from third parties are permissible under this policy and the general rule is that — whether given or received — any of these should be cleared first by Critica management. It is however never acceptable to…
- Give, promise, or offer, a payment, gift, entertainment, or hospitality with the expectation that a business advantage will be received, or to reward a business advantage already given
- Give or offer a payment, gift, entertainment or hospitality to a government official, agent or representative to ‘facilitate’ or expedite a routine procedure
- Accept a payment, gift, entertainment, or hospitality from a third party suspected of being offered with the expectation that it will obtain a business advantage
- Accept a payment, gift, entertainment or hospitality from a third party suspected of being offered or provided with an expectation that a business advantage will be provided in return
- Threaten or retaliate against a colleague who has refused to commit a bribery offence or has raised concerns under this policy
- Engage in any activity that could breach this policy.
Facilitation payments
Critica Group does not make or accept facilitation payments of any kind. These are typically small, unofficial, payments made to secure or expedite a routine action by a public official. They are not common in the UK and Ireland, but are more common in some of the other jurisdictions in which we operate. We should ensure that none of our intermediaries or agents ever breaches this prohibition.
Representative, agents, supplies and partners
All Critica staff must exercise due diligence to ensure bribes are not offered or given by partners, agents, representatives, intermediaries or suppliers.
Under the Bribery Act, it is unacceptable to turn a blind eye or allow representatives or associates to offer or accept bribes. All third party agreements must provide for termination in the event of corruption on the part of the third party.
Tendering and awarding contracts
Critica Group has a zero-tolerance approach towards anti-competitive behaviour, including any practice aiming to, or resulting in, restricting access to public procurement processes.
Conflicts of interest
Conflicts of interest can arise when a personal interest of a Critica staff member or representative conflicts with those of the business. These can be financial, professional, family, or other interests. In this situation, staff are expected to inform their managers immediately and provide sufficient details. No further involvement is permissible until the manager has reached a decision.
Financial control
Any payment or advantage granted in Critica’s name must have a lawful and defined purpose and comply with…
- International legislation regarding sanctions, embargoes, and the prevention of money laundering and the financing of terrorism
- Criticas’s validation and accounting processes (order, delivery, payment) and accounting processes described in Veolia’s purchasing processes.
