Purpose: This policy sets out MKSK Consulting’s standards on business ethics, anti‑corruption compliance, payment of commissions, gifts & hospitality (including for customers and Government Officials), and related obligations. It applies to all MKSK employees, contractors, directors, and third‑party intermediaries worldwide.
Contents
2. Our Standards & Applicable Laws
3. Zero‑Tolerance Prohibitions
4. Gifts, Hospitality & Entertainment
5. Commissions, Referrals & Third Parties
6. Dealings with Government & Public Sector
7. Charitable & Political Contributions
9. Financial Integrity & Record‑Keeping
10. Sales, Marketing & Competition
12. Reporting Concerns & Non‑Retaliation
1. Scope & Governance
MKSK Consulting Ltd (“MKSK”, “we”) maintains a robust ethics and compliance framework aligned to international best practice and UK requirements. This policy is approved by the Board and owned by the Compliance Lead. It supplements our Employee Handbook, Supplier Code, Modern Slavery Statement, and Information Security policies.
2. Our Standards & Applicable Laws
We conduct business with integrity, fairness, and transparency. We comply with all applicable laws, including (as relevant): the UK Bribery Act 2010 (including the corporate offence of failure to prevent bribery), the US Foreign Corrupt Practices Act (FCPA), the UK Criminal Finances Act 2017 (facilitation of tax evasion), anti‑money‑laundering and trade sanctions laws, competition laws, and public procurement rules. Where laws differ, we apply the higher standard.
3. Zero‑Tolerance Prohibitions
3.1 Bribery & Improper Advantages
- We prohibit offering, promising, giving, requesting, agreeing to receive, or accepting anything of value to obtain or retain business or an improper advantage—directly or via third parties.
- Facilitation payments (small payments to speed up routine actions) are strictly prohibited.
- Improper advantages include undue discounts, rebates, employment offers, internships, travel not tied to business purpose, or excessive hospitality.
3.2 Money Laundering & Sanctions
- No engagement with transactions that conceal the proceeds of crime or evade sanctions.
- Only use approved bank accounts in the name of the contracting party; no cash payments or unofficial side agreements.
4. Gifts, Hospitality & Entertainment
Modest business courtesies may build relationships but must never unduly influence—or appear to influence—decisions. All gifts/hospitality must be infrequent, proportionate, transparent, and for a legitimate business purpose.
4.1 Standard thresholds (commercial/private sector)
- Nominal gifts (e.g., branded items, working lunches) are permitted.
- Per‑person limit: £100 per event; annual cumulative limit: £250 per external individual or organisation.
- Cash or cash equivalents (e.g., gift cards) are not permitted.
- Events must be attended by MKSK staff; “no‑host” tickets are not permitted.
- All items must be pre‑approved and recorded (see 9).
4.2 Public sector & Government Officials
- Government Official includes any officer/employee of a government department or public agency, state‑owned enterprise, political party/candidate, or public international organisation.
- Default rule: No gifts, hospitality, travel, or entertainment beyond light refreshments at our premises.
- Any exception requires written pre‑approval from Compliance and must comply with local laws and the counterparty’s policy.
Note: Sponsoring travel, per diems, family members, or leisure activities is not permitted. Charitable donations must not be used as a substitute for hospitality (see 7).
5. Commissions, Referrals & Third Parties
- We only pay commissions, referral fees, or reseller margins to approved intermediaries under a written contract that sets legitimate, proportionate fees.
- Enhanced due diligence is required for high‑risk markets, government touchpoints, or where a third party was recommended by a public official.
- No contingency/success fees on public‑sector deals. No payments to shell companies, personal accounts, or offshore entities unrelated to the contract.
- Compensation must reflect bona fide services actually rendered at fair market value and be fully invoiced with sufficient detail.
6. Dealings with Government & Public Sector
- Strict compliance with public procurement rules; no access to confidential bid or source‑selection information.
- Accurate, complete, and timely invoicing and reporting.
- No use of lobbyists on MKSK’s behalf without Board‑approved mandate and registration where required. Employees must not lobby government in a personal capacity on MKSK matters.
7. Charitable & Political Contributions
- Corporate charitable donations and sponsorships require Compliance approval and must be transparent, documented, and not linked to obtaining business.
- MKSK does not make political donations. Personal political activity must not use MKSK funds, assets, or brand.
8. Conflicts of Interest
Team members must avoid situations where personal interests conflict—or appear to conflict—with MKSK’s interests. Disclose any potential conflicts to Compliance for guidance and mitigation (e.g., recusal, reassignment).
9. Financial Integrity & Record‑Keeping
- All transactions must be accurately recorded in MKSK’s books. No side letters, undisclosed rebates, or off‑book arrangements.
- Maintain a Gifts & Hospitality Register and Third‑Party Register with approvals and supporting documentation.
- Retention: keep relevant records for 7 years (or longer if required by law or contract).
10. Sales, Marketing & Competition
- No misleading claims or disparagement. Substantiate performance claims.
- Comply with competition/antitrust laws: no price‑fixing, bid‑rigging, market/customer allocation, or exchange of competitively sensitive information with competitors.
11. Training & Due Diligence
- Annual code‑of‑conduct and anti‑bribery training for employees in sales, delivery, procurement, finance, and leadership.
- Risk‑based due diligence for partners, resellers, agents, and subcontractors before engagement and periodically thereafter.
12. Reporting Concerns & Non‑Retaliation
We encourage prompt reporting of suspected violations. MKSK prohibits retaliation against anyone who raises a concern in good faith.
How to report
- Email: compliance@mksk.co.uk
- Confidential line (UK): +44 (0)20 08138 0318 (placeholder)
- Or contact any Director or the Compliance Lead.
13. Breaches & Enforcement
Breaches may result in disciplinary action (up to dismissal), termination of third‑party relationships, recovery of losses, and reporting to regulators or law enforcement. MKSK reserves the right to audit compliance with this policy.
14. Contact & Hosting URL
Questions? Contact compliance@mksk.co.uk
This page is intended for public disclosure to customers, partners, and auditors. A PDF version may be provided on request.
