Anti-Bribery, Corruption & Fraud Policy

Bribery and corruption remain major issues in world trade and have a detrimental impact on business by undermining good governance and distorting free markets. Clarks have a moral and legal obligation to combat bribery and comply with the anti-bribery laws of the countries and territories in which we do business including the UK Bribery Act 2010. The Act affects us, as a UK organisation, if bribery occurs anywhere in the world.

A bribe is a financial inducement or other reward that is offered to, given to, or received by an individual or company (whether directly or indirectly) to influence that individual or company to perform public or corporate functions or duties improperly.

Clarks has a zero tolerance policy towards bribery, whether direct or indirect and prohibits anyone acting on behalf of the Company from paying a bribe in connection with our business. The policy places the responsibility on Clarks and third parties acting on our behalf, to uphold this commitment to prevent, monitor and eliminate bribery, in accordance with the Bribery Act 2010. Employees and others acting for or on behalf of the organisation are strictly prohibited from making, soliciting or receiving any bribes or unauthorised payments.

Clarks are committed to transparent, proportionate, reasonable and genuine hospitality and promotional expenditure. Breaches of Anti-Bribery and Corruption policy by an employee will be treated as grounds for disciplinary action.

Every employee and individual acting on Clarks behalf is responsible for protecting our reputation and for conducting company business honestly and with integrity in line with our Code of Business Ethics principles. This helps to foster relationships of trust between Clarks, our business partners and customers. Clarks reserves the right to terminate contractual arrangements with any third parties acting for, or on behalf of, Clarks where there is evidence that they have committed acts or been involved in bribery. Employees and other individuals acting for the organisation should note that bribery is a criminal offence that may result in up to 10 years' imprisonment and/or an unlimited fine for the individual together with an unlimited fine for the organisation.

Our employees and others acting for, or on behalf of, Clarks are encouraged to report any suspected bribery or corruption to Our Compliance team will determine whether the concern requires escalation to the relevant authorities. Clarks will protect anyone who reports a concern in good faith from retaliation.