Last updated: 15/01/2026
Gil Stauffer UK Ltd (“Gil Stauffer”, “we”, “us”, “our”) is committed to conducting business ethically, transparently, and with integrity. We operate a zero-tolerance approach to bribery and corruption in all forms and are committed to complying with the UK Bribery Act 2010 and all applicable anti-bribery laws.
This policy applies to all employees, directors, agents, contractors, suppliers, and business partners acting on behalf of Gil Stauffer.
1. What Is Bribery?
A bribe is an inducement or reward offered, promised, or provided to gain any commercial, contractual, regulatory, or personal advantage.
Bribery can take many forms, including but not limited to:
- Cash payments
- Gifts or hospitality intended to influence decisions
- Facilitation payments
- Kickbacks or commissions
- Favourable treatment or services in exchange for advantage
2. Policy Statement
Gil Stauffer strictly prohibits:
- Offering, giving, requesting, or accepting bribes
- Facilitation payments of any kind
- Improper influence of public officials or private individuals
- Any form of corrupt business practice
We expect the same high standards from all third parties who work with or for us.
3. Gifts and Hospitality
Reasonable and proportionate business hospitality or promotional gifts may be offered or accepted where:
- They are of modest value
- They are not intended to influence a business decision
- They comply with local laws and business customs
- They are transparently recorded where required
Gifts or hospitality must never be offered or accepted during tendering, negotiations, or decision-making processes where they could be perceived as improper.
4. Facilitation Payments
Gil Stauffer does not make or accept facilitation payments, regardless of local customs or practices. Facilitation payments are unofficial payments made to secure or speed up routine actions and are considered bribes under UK law.
5. Third Parties and Business Partners
We conduct due diligence on third parties where appropriate and expect all suppliers, agents, and partners to:
- Act ethically and lawfully
- Comply with applicable anti-bribery legislation
- Avoid conduct that could expose Gil Stauffer to legal or reputational risk
Any breach of this policy by a third party may result in termination of the business relationship.
6. Responsibilities
All employees and representatives of Gil Stauffer are responsible for:
- Reading and understanding this policy
- Acting in accordance with its principles
- Reporting any suspected bribery or corruption
Management is responsible for promoting compliance and ensuring appropriate controls are in place.
7. Reporting Concerns
Any concerns or suspicions of bribery or corruption must be reported immediately. Reports can be made confidentially and without fear of retaliation.
Concerns may be raised with:
- A line manager
- Senior management
- london@gil-stauffer.com
Gil Stauffer will investigate all reports promptly and fairly.
8. Consequences of Breach
Any breach of this policy may result in:
- Disciplinary action, including dismissal
- Termination of contracts or partnerships
- Legal action where appropriate
9. Monitoring and Review
This policy is reviewed regularly and may be updated to reflect changes in legislation or business operations.
