Virgin Money has a legal, moral and social responsibility to identify and deter anyone who wants to use our company to commit any sort of financial crime.
So we take a zero tolerance approach toward bribery and corruption. Under our Anti-Bribery and Corruption policy, we don’t allow the offering or receiving of any sort of bribe or corrupt payment. This applies to employees, agents, intermediaries, consultants, distributors, sub-contractors and suppliers working for us.
Our employees must not:
Our employees must:
Virgin Money must carry out:
Our policies give clear guidance on how and when to declare gifts, and how to carry out and manage due diligence on an ongoing basis. They also offer guidance on sponsorship, charitable and political donations, including how to make sure they are approved, transparent and in line with the UK Bribery Act.
We regularly carry out risk assessments of our Anti-Bribery and Corruption framework.
We encourage employees worried about any sort of potential bribery or corruption to report this internally or by using our whistleblowing line. This gives colleagues a secure and confidential way to tell us about bribery or anything they feel is suspicious. We don’t tolerate victimisation or harassment of whistleblowers.
If one of our employees fails to comply with our Anti-Bribery and Corruption policy, we may take disciplinary action.
When we engage in business relationships with third parties, we make sure they have the necessary skills and experience to provide the services we pay them for. All our business partners have to be reputable and reliable with a good track record, and they must charge a fair market price for their services.
We expect all our potential and existing business partners to have the same ethical standards as Virgin Money. They must also comply with the UK Bribery Act and be able to meet our due diligence requirements quickly and efficiently.
Anti-bribery and corruption (AB&C) is how we describe the systems and controls we have in place to prevent Virgin Money or one of its employees breaching obligations under the Bribery Act 2010.
There are four key offences under the Act:
At Virgin Money Group we are committed to maintaining an anti-bribery framework in line with the UK Bribery Act 2010 (‘the Act’) and with the Financial Conduct Association (FCA)’s Senior Management Arrangements, Systems and Controls.
We have also considered: