Anti-Bribery Policy

Medway Medical has a zero tolerance of bribery and corruption.

Bribery is defined as “the giving, receiving, soliciting or promising of money, a gift or anything else of real or implied value as an inducement to do something that is dishonest, illegal or a breach of trust in order to secure business or a business advantage”.

Whilst Medway Medical respects the rules by which others conduct their own business, these are the principles by which we will conduct our business:

  • Fairly, honestly, openly and with integrity.
  • Not make bribes, nor will we condone the offering of bribes on our behalf.
  • Not accept bribes, nor will we agree to them being accepted on our behalf.
  • We will avoid appointing others to provide services for us or on our behalf who do not share these principles and who may harm our reputation.
  • Set out our processes for avoiding bribery and keeping to and supporting our values
  • Keep clear and updated records.
  • Make sure that all members of Medway Medical team and business associates know our principles.
  • Will at all times act with integrity and avoid conflict of interest and any actions or situations that are inconsistent with our Ethics and Conduct framework and professional obligations.


Medway Medical requires the following procedures to be implemented and maintained:

  • Strict compliance with this and related relevant policies
  • (where relevant) Training to allow recognition of, and avoidance of, bribery.
  • The provision of appropriate training is a key feature of our obligations under the Act and one which is monitored and audited.
  • Vigilance and reporting of any suspicion of bribery made immediately via email to
  • A record of bribery alerts should be kept in line with stated security policies
  • Rigorous investigation of any alleged bribery.
  • Firm disciplinary action against anyone found to be involved in bribery.

All of our business partners must be informed of this policy and must comply with this policy.

The policy applies to any director, officer, agent, employee or other person associated with or acting on behalf of Medway Medical.