Anti-Bribery and Corruption Policy
Apollo Accreditation
1. Position
We prohibit bribery and corruption in every form, in every country we operate in, without exception and without a threshold below which it is acceptable.
2. Why this is specific to our work
Our work involves influencing decisions made by regulators, awarding organisations and accreditation bodies. Influence is the service. That makes the line between legitimate advocacy and improper inducement the single most important line in this business.
Legitimate influence means evidence, argument and a submission that meets published criteria. Anything that seeks to move a decision by benefit rather than by merit is prohibited.
3. What is prohibited
Offering, giving, requesting or accepting anything of value intended to induce or reward the improper performance of a function, whether the recipient is a public official or not.
Facilitation payments of any size, including small payments to speed up a routine process.
Charitable or political donations used as a route to influence.
Using an intermediary to do anything we could not do ourselves.
4. Gifts and hospitality
Reasonable, proportionate and openly given hospitality in the ordinary course of business is permitted. Anything offered to or by a person connected to a live decision on a client submission is not.
| Situation | Position |
|---|---|
| Ordinary business meal, no live decision pending | Permitted, recorded if over a nominal value |
| Anything offered to a decision-maker on a live submission | Prohibited |
| Cash or cash equivalent, any amount | Prohibited |
| Gift where refusing would cause offence | Accept, declare, and pass to the organisation |
5. Third parties
Subcontractors, associates and referral partners are bound by this policy in writing. We assess them before engagement and we terminate where there is credible evidence of a breach.
6. Applicable law
We operate in Malta and the United Kingdom. The Criminal Code of Malta and the Bribery Act 2010 in the United Kingdom both apply to our conduct, and the Bribery Act has extraterritorial reach over conduct anywhere in the world by an organisation carrying on business in the United Kingdom.
7. Reporting
Report anything you are concerned about to info@apolloaccreditation.com. Reports can be anonymous. We do not retaliate against anyone reporting in good faith, and a report that turns out to be mistaken is not a disciplinary matter.
8. Review
Reviewed annually, and after any incident.