Fleet Evolution has implemented this policy to ensure the highest standards of honesty and integrity in its business.
We have assessed the risk to the business of acts of bribery and corruption and expect all employees and associated people acting on behalf of Fleet Evolution to comply with this policy and to ensure that no offence under the Bribery Act 2010 is committed for which Fleet Evolution would be liable. Failure to comply with this policy may constitute a serious act of misconduct which could result in the dismissal of an employee / worker or the cancellation of a contract with an associated person.
Bribery may be known as a bung, kickback, favour for cash, or other terms. It is generally defined as the giving or receiving of a financial inducement or other advantage in return for the improper performance of a relevant function or activity.
Examples of bribery include giving or receiving a financial inducement or other advantages to:
Bribes can be given to, or received from representatives of suppliers, contractors, public officials and clients amongst others.
Bribes do not have to involve cash payment and can include the giving or receiving of gifts, hospitality, entertainment or other benefits.
The Bribery Act 2010 makes it a criminal offence for an individual to offer or accept a bribe and is punishable by a fine and / or up to 10 years imprisonment.
The Act also states that an offence will be committed by a commercial organisation if they fail to prevent a person associated with the organisation from offering or accepting a gift in exchange for business.
Training on this policy, and on the risks our business faces from modern slavery in its supply chain, will be provided where needed. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
The prevention, detection and reporting of Bribery and other forms of corruption are the responsibility of all those working for Fleet Evolution, or under our control. All personnel are required to avoid any activity that might lead to, or suggest, a breach of this policy.
If you believe or suspect that a conflict with this policy has occurred, you must immediately notify HR.
Personnel who breach this policy will face disciplinary action; this could result in dismissal for gross misconduct.
Fleet Evolution keeps financial records and has appropriate controls in place to evidence the business reasons for making payments to third parties. Accordingly, you must ensure that all expense claims relating to hospitality or gifts incurred by you on behalf of Fleet Evolution for the benefit of a third party are submitted in accordance with our expenses policy and specifically record the reason for the expenditure.
Personnel for those who are acting on behalf of Fleet Evolution who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. Fleet Evolution encourages openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
Fleet Evolution is committed to ensure that no one suffers any detrimental treatment because of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavorable treatment connected with raising concern. If you believe you have received such treatment, you should inform your line manager.
Fleet Evolution will seek to assess the nature and extent of its exposure to the risks of internal and external fraud, bribery and corruption. It will regularly review these risks, annually, using information on actual or suspected instances of fraud, bribery and corruption to inform its review. They will put in place efficient and effective systems, procedures and internal controls to: encourage anti-fraud, bribery and corruption; and reduce the risks to an acceptable level.
In order that employees have the skills, knowledge and expertise to manage its risk effectively, it will provide induction and refresher training to help make employees aware of the risks of bribery and corruption, and of their responsibilities in preventing, detecting and reporting it.
They will regularly review and evaluate the effectiveness of its systems, procedures and internal controls for managing the risk of bribery. It will do this through risk management and assurance processes and audit arrangements.
Updated July 2025.
