Anti-Bribery and Corruption Policy
The purpose of this policy is to establish controls to ensure compliance with all applicable anti-bribery and corruption regulations and to ensure that Ligentia conducts business in a socially responsible manner.
Bribery and Corruption
Bribery means the offering or providing, promising, giving, accepting or soliciting of an advantage (loan, gift, trip, entertainment, donation, payment, or any other thing of value) as an inducement for an action which is illegal, unethical, a breach of trust, or to secure an improper advantage.
Acts of bribery are designed to influence individuals to act dishonestly in the performance or discharge of their duty.
Corruption means dishonest activity in which a director, executive, manager, employee or contractor of an entity acts contrary to the interests of the entity and abuses his/ her position of trust in order to receive some personal gain or advantage for him or herself or for another person or entity.
Employees and others acting for or on behalf of Ligentia must not engage in any form of bribery or corruption, either directly or through any other party (such as an agent or distributor). Specifically, employees must not bribe a foreign public official anywhere in the world.
Gifts and Hospitality
Employees and others acting for or on behalf of Ligentia are strictly prohibited from making, soliciting or receiving any bribes or unauthorised payments. As part of our anti-bribery policies, Ligentia is committed to only offer and receive transparent, proportionate, reasonable and legitimate hospitality, gifts and promotional expenditure or charitable giving.
A breach of this ethical behaviour policy by an employee will be treated as grounds for disciplinary action, which may result in a finding of gross misconduct and immediate dismissal.
Ligentia will not conduct business with service providers, agents or representatives that do not support and commit to follow Ligentia’s anti-bribery and corruption objectives.
Monitor and Review
The board of directors will monitor the effectiveness and review the implementation of this policy, considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.
This policy may be amended at any time
Ligentia Modern Slavery Statement 2019
Ligentia Group Limited (a company registered in England with number 6559662) on its own behalf and on behalf of its worldwide group companies (in this statement collectively identified as “we”, “our” or “Ligentia”), is committed to identifying and addressing modern slavery and human trafficking in all forms in their business practices.
Ligentia understands that modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
Modern slavery remains a hidden yet dangerous problem on our global society. We all have a responsibility to be vigilant in recognising and responding to the risks, however small, in our business and in the wider supply chain.
Ligentia has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
This is our second modern slavery statement and sets out the actions we have taken to prevent modern slavery and human trafficking in our business and supply chain since our last statement was published.
Ligentia’s structure and business
We are a solution-focused logistics supply chain provider, founded on the principles of professionalism, partnerships and strong systems. We are an asset-light and independent provider of cost-effective, lean and agile solutions, with a global footprint extending over 100 countries, covering our core markets of the UK and Europe, Asia and Australia.
Our capabilities include sea and air freight forwarding, warehousing and fulfilment, trucking, and supply chain management information systems.
We are very aware of the potential risks of modern slavery, especially in some of the geographies where we operate. No matter how small these risks may be, we are taking active steps to identify and where applicable mitigate them as quickly as possible.
Our policies on slavery and human trafficking
The policies we have in place and our anti-slavery statement reflect our commitment to:
- paying people fairly and properly for their work;
- acting ethically and with integrity in all our business relationships; and
- enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our business or supply chains.
Our main policies include:
- Fair Pay
Ligentia are committed to ensuring that all directly employed and contracted staff receive fair remuneration for the job they perform.
- Employee Awareness and Compliance
Our staff handbook sets out all our employment policies and procedures. It includes our expected standard of conduct, which incorporates our anti-slavery policy and measures.
Being aware of the contents of our employee handbook is one of our mandatory policies, which we expect all employees to observe; each employee signs a declaration when they join confirming their familiarity with our mandatory policies.
Most of Ligentia’s workforce is employed directly on a permanent or fixed term basis. Our recruitment takes place through a combination of direct advertising on our website and in industry publications/digital media; using reputable agencies and relying on referrals from employees within our organisation.
The firm only uses specified, reputable employment agencies and has a set of standard terms and conditions of business with each agency. We verify the practices of any new recruitment agency as part of our terms of business with them and before accepting workers from that agency.
All employees who join us are subject to checks to ensure they are genuine applicants operating as free agents with the required level of propriety. These include verification of identity, references, evidence of qualifications, criminal and financial checks. For the few roles in our business which are filled by contractors or agency workers, we ensure that similar checks to those for employees are carried out.
- Suppliers and partners
We operate a supplier and partner verification process, where we undertake a number of due diligence checks. For suppliers and partners where there is deemed to be an additional risk of slavery or human trafficking, supplementary checks are completed.
Ligentia’s suppliers and partners are an important part of our success and our culture. We expect them all to conduct their business with the same commitment to ethical business practices as Ligentia.
Ligentia and its suppliers and partners will:
- not use forced or compulsory labour, i.e. any work or service that a worker performs involuntarily or under threat of penalty;
- ensure that the overall terms of employment are voluntary; not hold passports of migrant workers;
- not pay fees to agents other than reputable temp worker agencies where there is an opportunity for workers to engage in temporary to permanent employment;
- comply with the minimum age requirements prescribed by applicable laws unless a specific contract contains stricter age requirements;
- compensate its workers with wages and benefits that meet or exceed the legally required minimum and will comply with overtime pay agreements;
- abide by applicable law concerning the maximum hours of labour – such as the provisions of Working time Directive(s) or other applicable laws; and
- keep records of, and be entirely transparent in complying with the above.
We have reviewed our supply chain protocols and continue to take the measures described above to reduce Ligentia’s exposure to modern slavery and human trafficking issues. We disseminate our policies through our supply chain and regularly review our supply chain and its compliance with these policies.
The specific measures we are taking through the next financial year include:
- continuing to identify and assess any key risk areas in our supply chains.
- reiterating to all current critical suppliers their required compliance with Ligentia’s zero tolerance approach to human rights abuses and, where appropriate requesting details of their due diligence procedures both for internal compliance and within their own supply chains.
- implementing the Ligentia Anti-Slavery Policy and providing training for all our managers, both new and existing.
- including a specific requirement in our procurement vetting process for prospective suppliers to disclose their position on human slavery and trafficking and provide policies/statements as appropriate. continuing to safeguard whistleblowers via our ‘Whistleblowing Policy’.
- To renew contracts with Tier 1 overseas agents incorporating Ligentia’s Modern Slavery policy. Modern slavery collateral to be displayed in all offices and on LINKS the Ligentia intranet site.
- Tier 1 UK warehouse partners to be presented with new contracts including modern slavery policy. To identify and roll out to Tier 2 suppliers in the UK and overseas the Ligentia Modern Slavery policy.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Ligentia’s slavery and human trafficking statement for the financial year ending 31 December 2018. It has been approved by the Ligentia Group Limited’s board, who will review and update it annually, and has been personally executed by Rakesh Patel, Chief Financial Officer and statutory director of Ligentia Group Limited.
Group Finance Director
11th June 2019
Corporate Social Responsibility Policy Statement
A big part of making Ligentia a great place to work is acknowledging our responsibilities in monitoring good ethical behaviour, concern for employees’ health and safety, and care for the environment and community.
Ligentia recognises that our people are our greatest asset and key to continued growth and success, and as such we are committed to providing careers and working environments in which our people can reach their fullest potential. The ongoing development of our employees is vital to our success and the investments we have made in the last 20 years will continue.
Developing future talent is fundamental to Ligentia. New graduate recruitment schemes have been introduced within the business alongside accredited training for all staff to achieve recognised professional qualifications that are relevant to the sector.
Ligentia is committed to providing an equal opportunity and promoting diversity to all existing and prospective employees without discrimination based on religion, disability, gender, age, marital status, sexual orientation, race and ethnicity.
Ligentia has a commitment to keeping employees informed of Group affairs through news circulars and regular staff meetings. Employees can access the company intranet, Lotus, to obtain general information on the Group. Employees are encouraged to discuss operational issues with their line management and to suggest ways to improve performance and efficiency.
Health, Safety and Welfare at Work
Ligentia operates a comprehensive Health and Safety Policy and works to ensure a safe environment is achieved for employees and visitors. It is the policy of Ligentia to create and improve standards of health and safety, which will lead to the avoidance and reduction of risks and to ensure that the company complies with all Health and Safety legislation. A detailed Health and Safety Policy Statement is held at all branch premises and displayed on notice boards.
Health and Safety, and Fire Officers actively implement the policies, standards and procedures in all Ligentia branches. They are supported by dedicated Health and Safety managers who are professionally qualified. Ligentia makes every reasonable and practicable effort to provide safe and healthy working conditions in all its offices. It is the duty of all employees to exercise responsibility and to do everything they can to prevent injury to themselves and to others. The policy standards and procedures are communicated to employees through contracts of employment, staff handbooks, notice boards and staff training.
Each year Ligentia supports individual charities though the proceeds of team events as well as by donating directly to charities through internal cost saving initiatives i.e. sending e-cards rather than Christmas cards.
Ligentia respects the environment and is committed to reducing the environmental impact of our global operations. The Ligentia senior management team is engaged in a continuous programme of improvement and are entrusted to proactively address issues that may adversely affect environmental performance within their business channel.
Furthermore there are a number of receptacles positioned throughout our offices to encourage the recycling of paper, cans, glass and plastics. Old IT equipment is also donated or recycled and all lighting and electronic equipment is switched off at night.
Ligentia is committed to sustainable procurement, as such all departments ensure goods and services purchased are the most environmentally friendly solutions and where possible buy fair trade, recycled and recyclable products.
This policy is actively communicated, reviewed and improved annually by a dedicated senior management team.
Whistleblowing Policy and Procedure
1.1.1 General statement
We are committed to conducting our business in a responsible way and to ensuring that the public interest is safeguarded. The purpose of this Policy is to encourage our employees to raise legitimate concerns in a responsible way where they believe that there has been some form of malpractice.
1.1.2 What is Whistleblowing?
Whistleblowing is the reporting of suspected wrongdoing or dangers in relation to our activities. This includes bribery, fraud or other criminal activity, miscarriages of justice, health and safety risks, damage to the environment and any breach of legal or professional obligations.
1.1.3 General principles
1) You must only raise concerns under this policy if there is a public interest involved. Concerns which relate to a personal grievance or private dispute should be dealt with under the grievance procedure.
2) Staff must not threaten or retaliate against whistleblowers in any way. If you are involved in such conduct you may be subject to disciplinary action. In some cases the whistleblower could have a right to sue you personally for compensation in an employment tribunal.
3) Abuse of this procedure by maliciously or mischievously raising unfounded allegations, either internally or externally, will be regarded as a serious disciplinary offence and may result in dismissal.
4) Where an allegation is made, the person or persons against whom the allegation is made shall be informed of the allegation and the evidence supporting it, and shall be allowed to comment before the investigation is completed.
5) Any allegation of malpractice shall be treated in the strictest confidence and investigated immediately. The identity of the individual raising the complaint shall not be disclosed to the alleged perpetrator of malpractice without that individual’s prior approval, unless this is incompatible with a fair investigation. You will be informed of the need to disclose your identity in any event.
6) If you make an allegation you must have a reasonable belief that the allegation is true and it must not be made for personal gain
1) The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator. We strongly encourage you to seek advice before reporting a concern to anyone external. Public Concern at Work operates a confidential helpline on 020 74046609, or by email email@example.com
This procedure applies to the following allegations:
- that a criminal offence has been, is being, or is likely to be committed;
- that a person has failed, is failing, or is likely to fail to comply with any legal obligation to which they are subject;
- that a miscarriage of justice has occurred, is occurring, or is likely to occur;
- that the health and safety of any individual has been, is being, or is likely to be endangered;
- that the environment has been, is being, or is likely to be damaged;
- that information tending to show any matter falling within one of the above categories has been, is being, or is likely to be deliberately concealed.
2) In the first instance, you should make any allegation covered by this procedure in writing to your Manager stating clearly that you are making an allegation under the protection of the Whistleblowing procedure.
3) A record will be made of receipt of the disclosure and we will either investigate the disclosure or arrange for an appropriate member of the senior management team to do so.
4) Once the investigation is completed, we will inform you, subject to any third party rights, of the outcome of the investigation.
5) If you have any concerns or complaints about the manner in which you feel you are being treated because you made the disclosure, whether by the alleged wrongdoer or by any colleagues, you should raise this with a member of the senior management team and it may be dealt with as a disciplinary matter in relation to such individuals.
6) If you are dissatisfied with the outcome of the investigation or feel unable to report it to your Manager in the first instance, disclosure should be made in writing to the appropriate Managing Director, who will investigate the matter and report back to the individual. The decision of the Managing Director will be final.