Section 1.0 About Us

AliumBlue is a niche partnership of experienced regulated infrastructure sector specialists, providing expert advice to large infrastructure organisations in road, rail, energy, and water. Our Partners are a group of people with a common ethic and complimentary experiences, we work as a collective to offer professional services at a strategic level to support clients in better decision making. We apply and share our knowledge of strategic and regulatory planning, risk and operational management, governance and best practice with our clients. 

Section 2.0 About this document

This document sets out our approach to complying with the Bribery Act 2010 and conducting business with honesty, integrity and transparency. We are committed to applying the UK government's 7 principles of public life in the way we do business:

• Selflessness.
• Integrity.
• Objectivity.
• Accountability.
• Openness.
• Honesty.
• Leadership.

We will ensure that Partners and Associates are aware of the partnership's business principles and this policy. All suppliers of goods and services will be required to confirm their willingness to adhere to this policy.

Section 3.0 Corrupt practices

The partnership forbids engagement, either directly or indirectly, in any corrupt business practices by its partners, employees, subcontractors or associates acting on its behalf. Such practices may include, but are not limited to:

• Offering, giving or accepting gifts or payments that constitute a bribe or could be regarded as such.
• Collusion.
• Extortion.
• Fraud.
• False claims.
• Dishonesty.
• Other improper rewards aimed at unfair competitive advantage.

Any demand for, or offer of, a bribe or inducement to act must be rejected immediately and reported to a Partner.

The partnership does not differentiate between a facilitation payment and a bribe – both are illegal – even where a payment may conform with what is considered acceptable under local law.

Section 4.0 Conflict of Interest

All Partners and Associates are required to avoid any contact that might lead to, or suggest, a conflict of interest between their personal activities and the business of AliumBlue or its clients.

• All Partners and Associates are required to disclose family links or close relationships with any relevant decision-makers of a client, supplier or competitor organisation.
• This includes financial interests in a client, supplier or competitor organisation and activities undertaken on behalf of a client or another party in such a way that the trust vested in AliumBlue by a third party (client or other business partner) may be abused.

Section 5.0 Transparency 

The partnership will conduct relationships with clients and business partners in the spirit of transparency, openness and trust, whilst at the same time having due regard to considerations of commercial or personal confidentiality.

• The partnership does not permit the establishment or maintenance of any undisclosed or unrecorded account, fund, asset or activity, and insists that proper and full records must be made of all transactions on behalf of the partnership.

Section 6.0 Responsibility for the policy

The partnership has overall responsibility for ensuring this policy complies with our business integrity and anti-bribery obligations, and that all those under our control comply with it.

• The partnership has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it and reviewing its effectiveness in ensuring we are countering the risk of bribery and maintaining integrity in the business.

Section 7.0 Compliance with the policy

We must all ensure that we read, understand and comply with this policy. The prevention, detection and reporting of bribery and breaches of business integrity in any part of the partnership or supply chains is the responsibility of all of us.

• You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
• If you believe or suspect that a conflict with this policy has occurred or may occur in the future the Partners must be notified at the earliest opportunity.
• Any concerns, issues or suspicion of bribery in any part of the partnership or supply chains of any supplier must be notified at the earliest opportunity.
• If you are unsure about whether a particular act within any tier of our supply chains constitutes bribery or a breach of business integrity, raise it with one of the Partners.
• We will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. No one will suffer any detrimental treatment from reporting in good faith their suspicion that bribery or breach of business integrity is, or may be, taking place in any part of our business or supply chains.

Section 8.0 Breach of the policy

Any Partner or Associate found to have breached this policy will be subject to disciplinary action.

• The partnership will terminate the contract of any supplier found to be operating in a manner that would cause AliumBlue to not comply with this policy or the Bribery Act.

This policy is communicated to all our Partners and Associates and is available to other interested parties upon request. This policy and the associated business management system is reviewed annually to ensure that it remains appropriate to our strategic direction and is suitable, adequate and effective.

Policy authorised by

Signature         Adrian Rees    Wendy Staden    Adrian Kennedy    Vicky Allen    James Elliott    

Name                 Adrian Rees, Wendy Staden, Adrian Kennedy, Vicky Allen, James Elliott

Date                   3rd July 2024