Our Policies

 

Anti-Bribery and Corruption Policy

Introduction

Whoever we may deal with, and wherever we may operate, we are committed to doing so lawfully, ethically and with integrity. As part of this commitment, all forms of bribery and corruption are unacceptable and will not be tolerated. We must not, and we must ensure that any third party acting on our behalf does not, act corruptly in our dealings with any other person.

This anti-bribery and corruption policy set out Dingo Recruitments policies to prevent acts of bribery and corruption. These policies and procedures have been designed to comply with legislation governing bribery and corruption on a global basis.

This policy provides guidance on the standards of behaviour to which we must all adhere and most of these reflect the common sense and good business practices that we all work to in any event. This policy is designed to help you to identify when something is prohibited so that bribery and corruption are avoided and provide you with and guidance if you are unsure about whether there is a problem and you need further advice.

Who this policy applies to

The fundamental standards of integrity under which we operate do not vary depending on where we work or who we are dealing with. This policy applies to all Dingo Recruitment employees (full and part-time) and temporary workers (such as consultants or contractors) (together referred to as "employees" In this document) across the group no matter where they are located or what they do. It is the responsibility of each of us to ensure that we comply with these standards in our daily working lives. This policy sets out a single standard that all employees must comply with, regardless of whether local law or practices might permit something to the contrary.

Part of Dingo Recruitments commitment to prevent bribery and corruption is to ensure that the people acting on our behalf also do so in compliance with effective anti-bribery and corruption policies. Accordingly, where we engage third parties such agents, distributors or joint venture partners, we have obligations to complete sufficient due diligence when entering into arrangements to ensure that they are not acting corruptly and to periodically monitor their performance to ensure ongoing compliance. In short, if we can't do it, neither can they.

Failure to comply with this policy, whether or not this is intentional, may lead to disciplinary action (up to and including dismissal), and criminal liability for the individual involved (up to and including imprisonment). Employees will be required to confirm that they have read and understood the policy and that they comply with its terms as part of their ongoing employment assessments processes. In addition, relevant employees will be required to attend training to support the guidance in this policy.

What is bribery? Bribery involves the following;

When a financial or other advantage is offered, given or promised to another person with the intention to induce or reward them or another person to perform their responsibilities or duties improperly (it does not have to be the person to whom the bribe is offered that acts improperly); or

When a financial or other advantage is requested, agreed to be received or accepted by another person with the intention of inducing or rewarding them or another person to perform their responsibilities or duties inappropriately (it does not have to be the person who receives the bribe that acts improperly).

It does not matter whether the bribe is:

Given or received directly or through a third party (such as someone acting on Dingo Recruitments behalf, for example, an agent, distributor, supplier, joint venture partner or other intermediaries); or

For the benefit of the recipient or some other person.

Bribes can take many forms, for example:

  • Money (or cash equivalent such as shares);
  • Unreasonable gifts, entertainment or hospitality;
  • Kickbacks;
  • Unwarranted rebates or excessive commissions (e.g. to sales agents or marketing agents);
  • Unwarranted allowances or expenses;
  • “Facilitation” payments/ payments made to perform their normal job more quickly and/or prioritise a particular customer;
  • Political/charitable contributions;
  • Uncompensated use of company services or facilities; or
  • Anything else of value

This policy applies to both the public and private sectors. Dealing with public officials poses a particularly high risk in relation to bribery and corruption and specific guidance when dealing with public officials is set out below.

A breach of bribery laws can result in fines for both the company and the individual and in some jurisdictions could also result in imprisonment.

How do I know if something is a bribe?

In most circumstances, common sense will determine when a bribe is being offered. However, here are some questions you should ask yourself if in doubt:

Am I being asked to pay something or provide any other benefit over and above the cost of the services being performed, for an example an excessive commission, a lavish gift, a kickback or make a contribution to a charity or political organisation?

Am I being asked to make a payment for services to someone other than the service provider?

Are the hospitality or gifts I am giving or receiving reasonable and justified? Would I be embarrassed to disclose them?

When a payment or other benefit is being offered or received, do I know or suspect it is to induce or reward favourable treatment, to undermine an impartial decision-making process or to persuade someone to do something that would not be in the proper performance of their job?

Policies and procedures General prohibition

All forms of bribery and corruption are prohibited. We will not tolerate any acts of bribery or corruption. Any breach of this policy or local law could result in disciplinary action being taken and ultimately could result in dismissal.

A bribe does not actually have to take place – just promising to give a bribe or agreeing to receive one is prohibited.

Bribery is prohibited when dealing with any person whether they are in the public or private sector and the provisions of this policy are of the general application. However, many countries have specific controls regarding dealing with public officials and this policy includes specific requirements in these circumstances.

Gifts, Hospitality and Expense

Giving or receiving gifts or hospitality is often an important part of maintaining and developing business relationships. However, all gifts and hospitality should comply with Dingo Recruitments Hospitality and Expenses Policy and local laws.

Lavish or unreasonable gifts or hospitality, whether these are given or received, are unacceptable as they can create the impression that we are trying to obtain or receive favourable business treatment by providing individuals with personal benefits. In addition, gifts and hospitality can themselves be a bribe. Be careful to avoid even the appearance that the giving or accepting of gifts or hospitality might influence the decisions you take on behalf of Dingo Recruitment.

Facilitation Payments

Facilitation payments are any payments, no matter how small, given to an official to increase the speed at which they do their job. For example, this could include speeding up customers clearance.

All facilitation payments are generally prohibited. However, your safety is our primary concern and we understand that there may be circumstances in which you have no alternative but to make a facilitation payment in order to protect against loss of life, limb or liberty. Any request for a facilitation payment should be reported to info@dingorecruitment.com.

Agent, Distributors, Suppliers and joint venture partners

Dingo Recruitment could be liable for the acts of people that act on our behalf. This includes agents, distributors, suppliers and joint venture partners (together referred to as “third parties”). As such we are committed to promoting compliance with effective anti-bribery and corruption policies by all third parties acting on behalf of Dingo Recruitment.

All third parties should be made aware of the terms of Dingo Recruitment of their obligations to comply with this policy. All arrangements with third parties should be subject to clear contractual terms including specific provisions requiring them to comply with minimum standards and procedures in relation to bribery and corruption.

You must not engage any third party who you know or reasonably suspect of engaging in bribery.

Appropriate due diligence should be undertaken before any third parties are engaged. The appropriate level of due diligence will vary depending on the circumstances and you should use your judgment on a case by case basis.

Questions you should be asking yourself include:

  • Who are they – have I seen documents evidencing that they are who they say they are?
  • Are they established with a good reputation or are they more obscure so that I need to do more to find out about them?
  • Do they operate in a territory where bribery is prevalent?
  • Are they happy to sign a contract agreeing to comply with anti-bribery procedures? Do they have their own anti-bribery programme?
  • Have I done basic searches such as Google searches, business directory searches, etc?
  • Are they inconsistencies between the provider of the services and the person I am paying?
  • Are commissions/payments in line with generally accepted market practices?
  • Some high-risk transactions will require further due diligence which may require an independent investigation. Employees will be provided with helpful guidance and checklists where appropriate to support the due diligence process.
  • Entering into any joint venture arrangement without prior approval from Group Legal is prohibited.

All payments are commissions to third parties must:

Be made in accordance with the Group Authority Framework and the local policies relevant in your business as set by your line manager;

Be made via bank transfer through the accounts payable system and be fully accounted for;

Must be in line with generally accepted rates and business practice for the service in question and should not be unjustifiably excessive or unsupportable; and

Must be made in accordance with the terms of the contract with the person or company providing the services.

If you have any concerns that arrangements with a third party are not in accordance with this policy, you should ask your local anti-bribery and corruption officer for help.

Dealing with public officials

Although this policy applies to both public and private sectors, dealing with public officials poses a particularly high-risk in relation to bribery due to the strict rules and regulations in many countries.

Public officials include those in government departments, but also employees of government-owned or controlled commercial enterprises, international organisations, political parties and political candidates.

The provision of money or anything else of value, no matter how small, to any public official for the purpose of influencing them in their official capacity is prohibited.

Whistleblowing

Dingo Recruitment is committed to ensuring that employees can speak up with confidence If they have any concerns or need to ask for help. If you suspect or observe anything that you think might be in contravention of this policy, you have an obligation to report it. You should raise your concerns with your local anti-bribery and corruption officer in the first instance. Alternatively, you can report your concerns under the Whistleblowing Policy.

Dingo Recruitment will not tolerate retaliation in any form against anyone raising concerns or reporting what they genuinely believe to be improper, unethical or inappropriate behaviour. All reports will be treated confidentially.

Modern Slavery Policy & Statement

This statement is issued by Dingo Recruitment Services Limited, which includes its recruitment division. In all statements, the meaning and purpose will be on behalf of the company and its subsidiary division. The information included in the statement refers to the financial year 2018.

Organisational structure

Dingo Recruitment is a solely owned recruitment agency. It operates 365 days of the year, although work can be seasonal.

Dingo Recruitment has one UK only based operational location:

Head Office: 432 – 434 Streatham High Road, London SW16 3PX. This is the main administrations and operations centre. This office operates Monday – Friday, 9 am – 5 pm.

Dingo Recruitment supplies labour to such professions but not limited to; Labourers, Teachers, Carpenters, Social Workers, Physiotherapists, Removalists, Landscape Gardeners, Teaching Assistants, Butchers, Sales and Electricians. These locations vary but are generally in the UK.

Definitions

Dingo Recruitment considers that modern slavery encompasses:

  • Human trafficking;
  • Forced work, through mental or physical threat;
  • Being owned or controlled by an employer through mental or physical abuse of the threat of abuse;
  • Being dehumanised, treated as a commodity of being bought or sold as property;
  • Being physically constrained or to have a restriction placed on freedom of movement.

Commitment

Dingo Recruitment acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. Dingo Recruitment understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chain.

Dingo Recruitment does not enter into business with any other organisations, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided by Dingo Recruitment in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The company strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom.

Supply Chains

In order to fulfil its activities, Dingo Recruitment main supply chains include those related to labour only in the United Kingdom. Suppliers generally engage staff from the United Kingdom and West Africa. No second-tier contractual arrangements are in place nor entertained.

Potential Exposure

Dingo Recruitment considers it has minimal risk or exposure to the risk of slavery and human trafficking. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

Steps

  1. Dingo Recruitment carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.
  2. Dingo Recruitment has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
  3. In accordance with section 54(4) of the Modern Slavery Act 2015, Dingo Recruitment has taken the following steps to ensure that modern slavery is not taking place.
  4. Reviewing our supplier procedures of employment including full vetting and checking of staff members right to work.
  5. Regular checking of passports and immigration documents and the right to work status.
  6. Checking rates of pay

Key Performance Indicators

Dingo Recruitment has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in its business or supply chains.

Reviewing our supplier procedures of employment including full vetting and checking of staff members right to work.

Regular checking of passports and immigration documents and the right to work status.

Checking rates of pay

Policies

Dingo Recruitment does not currently have formatted policies which define its stance on modern slavery. However, its statement in the above section entitled ‘Commitment' is the basis for its ethos on this matter.

Furthermore, it includes its commitment to its employment strategy and is accordingly diligent in its application for its procedures and mechanisms.

Slavery Compliance Officer

Dingo Recruitment has a Slavery Compliance Officer – Mr D Field – to whom all concerns regarding modern slavery should be addressed and who will undertake relevant action with regard to Dingo Recruitments obligations in this regard.

This statement is made in pursuance off Section 54(1) of the Modern Slavery Act 2015 and will be reviewed of each financial year.

Sustainability Policy

This statement is issued by Dingo Recruitment Services Limited, which includes its recruitment division. In all statements, the meaning and purpose will be on behalf of the company and its subsidiary division. The information included in the statement refers to the financial year 2018.

Introduction

Dingo Recruitment Services Limited is committed to promoting sustainability throughout the company. Concern for the environment and promoting a boarder sustainability agenda are integral to Dingo Recruitment Service Limited professional activities, management, staff and sub-contractors. We aim to follow and promote good sustainability practice, to reduce the environmental impact of all our activities and to help our clients and partners do the same.

Aim

The aim of this document is to follow and promote good sustainability practice, to reduce the environmental impact of all our activities and to help our clients and partners do the same.

Principles

  • Our sustainability policy is based on the following principles:
  • To comply with and exceed where practicable, all applicable legislation, regulations and codes of practice
  • To integrate sustainability considerations into all our business decisions
  • To ensure all staff and sub-contractors are fully aware of our sustainability policy and are committed to implementing and improving it.
  • To minimise the impact on the sustainability of all office and transportation activities.
  • To make clients, sub-contractors and suppliers aware of our sustainability policy and encourage them to adopt sound sustainable practices.
  • To review, annually report and to continually strive to improve our sustainability performance,
  • Travel to Meetings

To put these principles into practice we will:

Walk, cycle and/or use public transport to attend meetings, site visits etc apart from in exceptional circumstances where the alternatives impractical and/or cost prohibitive.

Avoid physically travelling to meetings etc where alternatives are available and practical e.g. teleconferencing, video conferencing or webcams, and efficient timing of meetings to avoid multiple trips. These options are also often more time efficient, whilst not sacrificing the benefits of regular contact with clients and partners.

To reduce the need for our staff to travel by supporting alternative working arrangements e.g. home working etc and promote the use of public transport by locating our office's inaccessible locations.

Purchase of Equipment and Consumption of Resources

Energy, Office Equipment and House Keeping

Minimise the use of paper and other office consumables, for example by double-siding all paper used, and identifying opportunities to reduce waste.

Reduce the energy consumption of office equipment by purchasing energy efficient equipment and good housekeeping.

Working Practices and Advice to Clients

Undertake voluntary work with the local community and/or environmental organisations

Ensure that any associates we employ take account of sustainability issues in their advice to clients