Anti-Bribery & Corruption Policy
(External agents/intermediaries)
Compliance with bribery and corruption laws is critical to Clarks. To raise awareness, protect our reputation and avoid potential liability as a result of bribery or corruption involvement by any of our business partners we provide these requirements to all agents and intermediaries.
As a business partner of Clarks, you are an ‘associated person’ under the Bribery Act 2010 (BA 2010). As such, we can be held accountable for the actions you take on our behalf. It is therefore imperative that you:
- understand and follow the same laws and policies that apply to us and our staff
- recognise when bribery risks arise and know how to behave appropriately and in accordance with our policies in such situations
- make it clear to others that you and your business do not conduct business in an unethical manner, and
- take steps to reduce the risk of unwittingly committing bribery
There are 4 offences under the BA 2010 and violations are criminal offences with severe penalties for companies and individuals. They can lead to liability for us and for you and as such would constitute grounds for immediate termination of our contract with you.
By following our policies you can help ensure compliance with anti-bribery and corruption laws.
What this means for you
We expect you to be as committed to preventing bribery as we are. Bribery is never acceptable - we operate a zero tolerance policy.
A big part of our bribery and corruption prevention strategy is ensuring you are aware of what is and isn’t acceptable and you know what to look out for - so you can let us know about any potential indicators of bribery and corruption you identify.
What must you do?
All our staff, and you as our business partner, have an obligation to report actual or potential suspicions of bribery or corruption. If, having reviewed our policies and followed our procedures, you are still unsure as to whether you can go ahead with a certain activity, always check first with ethics@clarks.com.
If you are offered anything that feels like a bribe or are unsure about whether you can accept something offered to you by a third party, you should discuss this matter with ethics@clarks.com at the earliest opportunity. You should not accept it unless ethics@clarks.com has confirmed that we will not contravene BA 2010 by you doing so.
Alternatively, if you know or have formed a suspicion that another person is engaged in bribery or corruption you must report this promptly to ethics@clarks.com.
For full details of the offences, terminology and more details about what would constitute an issue contact ethics@clarks.com.