Call us on 01707 385 226

Anti-Bribery Policy

HENLEYS MEDICAL SUPPLIES ANTI BRIBERY POLICY

In compliance with the Bribery Act 2010 no employee should directly or indirectly offer, promise, give or demand a bribe or other undue advantage to obtain or retain business or gain other improper advantage. All offers of bribes from third parties must be reported to the Company. You must not accept or agree to accept any offer of gifts or services from customers, suppliers, distributors, or any person having similar connections to the Company without prior consent from a Director. A breach of this rule may give rise to disciplinary action which may lead to your dismissal without notice.

ACTIVITY PERMITTED Gifts/Samples:

  • Minimal value branded promotional items.
  • Free products/samples for evaluation to be a reasonable value/quantity (requests should be approved by the Sales and Marketing Director or the Managing Director).

ACTIVITY NOT PERMITTED Gifts:

  • No Gifts may be given to customers.
  • Tickets to sporting events or the theatre.
  • Golf or other activity outings where Henleys pays for the Health Care Professional (from now on referred to as HCP in this document) or Government Official.
  • Gifts/product given to any HCP or Government Official in order to obtain or keep business or to obtain some improper advantage except for genuine evaluations.
  • Gifts/products given as a “thank you” for the purchase of Henleys products.
  • Gifts of cash or cash equivalents, such as gift certificates.
  • Gift giving contrary to the regulations or industry codes of conduct of the country where the HCP is licensed to practice (notwithstanding the items listed under the “Permitted” column).

ACTIVITY PERMITTED Business Courtesies:

  • Meals or other modest hospitality in conjunction with a meeting when the meeting is directly related to performing a contract or the promotion, demonstration or explanation of Henleys products. The meeting should occur close to the HCP’s (or Government Official’s) place of business.
  • Meals or other hospitality in conjunction with a professional society meeting, product training, education meetings or similar event that are modest in amount according to local standards. (Please get authorisation from the Sales & Marketing Director for Dinner, Lunch, Snacks and/or Refreshments. Such expenses should be infrequent).

ACTIVITY NOT PERMITTED Business Courtesies:

  • Travel and lodging expenses unless there is a legitimate business need (e.g. plant tour, product training, educational meeting or demonstration of non portable equipment).
  • Entertainment or recreational activities (unless an exception has been obtained in writing from the Managing Director).
  • Any business courtesy to any HCP or Government Official in order to obtain or keep business or to obtain some improper advantage.
  • Any business courtesy to the spouse or guest of a HCP, or any other person, that does not have a bona fide interest in the subject of the meeting or event.
  • Business courtesies that are contrary to the regulations of the country where the HCP is licensed to practice.

ACTIVITY PERMITTED (if permission granted by the Sales and Marketing Director or Managing Director) Medical Conferences or Congresses:

  • Event-level sponsorship of nationally and regionally-recognized third-party conferences or congresses dedicated primarily to promoting objective scientific and educational activities and discourse.
  • Payment of reasonable educational grants to: (1) professional medical societies; (2) training institutions; or (3) healthcare institutions; for the registration, travel and lodging of attendees to such conferences or congresses (provided that the choice of candidates to attend such conferences or congresses resides exclusively with the society or institution).
  • Hosting modest meals and receptions for conference/congress attendees if consistent with the sponsor’s guidelines and subordinate in time and focus to the purpose of the conference/congress. The expense limits noted above apply.
  • Purchase of advertisements and booth space for Henleys displays at fair market value at conferences/congresses.

ACTIVITY NOT PERMITTED Medical Conferences or Congresses:

  • Any financial sponsorship involving the direct payment or reimbursement of a HCP’s expenses to attend third-party conferences or congresses.
  • Any financial support for the spouse or guest of a HCP that does not have a bona fide interest in the subject of the meeting or event.
  • Any educational grant or other financial support that is contrary to the regulations of the country where the HCP is licensed to practice.
  • Educational grants given to any HCP or Government Official in order to obtain or keep business or to obtain some improper advantage.
  • Side trips, sight-seeing or stop-overs.
  • Per diem payments.

ACTIVITY PERMITTED (if permission granted by the Sales and Marketing Director or Managing Director) Henleys Sponsored Training and Education:

  • Provision of company-sponsored training on the safe and effective use of Henleys products conducted in clinical, conference, hotel or other setting conducive to the effective transmission of knowledge.
  • Payment of reasonable travel and hospitality in the form of meals and receptions in connection with these programs provided it is subordinate in time and focus to the educational/training purpose. The expense limits noted above apply.
  • The need for any training or educational program must be adequately documented.
  • The support must comply with the regulations of the country where the HCP is licensed to practice.

ACTIVITY NOT PERMITTED Henleys Sponsored Training and Education:

  • Any financial support to the spouse or guest of a HCP that does not have a bona fide interest in the subject of the meeting or event.
  • Any payment, including travel and hospitality that is contrary to the regulations of the country where the HCP is licensed to practice.
  • Company training given to any HCP or Government Official in order to obtain or keep business or to obtain some improper advantage.
  • Side trips, sight-seeing or stop-overs.
  • Per diem payments.

ACTIVITY PERMITTED (if permission granted by the Sales and Marketing Director or Managing Director) Educational and Research Grants:

Only grants intended to support bona fide educational or research programs are permitted. Clinical research grant applications must be approved by the Sales and Marketing Director or Managing Director.

ACTIVITY NOT PERMITTED Educational and Research Grants:

  • Any educational grant or other financial support that is contrary to the regulations of the country where the HCP is licensed to practice.
  • Grants given to any HCP, Government Official or institution in order to obtain or keep business or to obtain some improper advantage.

ACTIVITY PERMITTED (if permission granted by the Sales and Marketing Director or Managing Director) Charitable Donations:

Charitable donations are permitted only if the donation is intended for a charitable or other philanthropic purpose and has the approval of the Sales and Marketing Director or the Managing Director.

ACTIVITY NOT PERMITTED Charitable Donations:

Charitable donations given to any HCP, Government Official or institution in order to obtain or keep business or to obtain some improper advantage.

ACTIVITY PERMITTED (if permission granted by the Sales and Marketing Director or Managing Director) Consulting Arrangements:

  • Compensation of individuals, including physicians or other customers, for bona fide consulting and personal services where the services have value to Henleys and the fees are based on services actually provided.
  • All consulting arrangements must be in writing and consistent with the regulations of the country where the HCP is licensed to practice or customer resides.
  • Henleys must make the payment and it must be made with a company cheque or by wire transfer.
  • Payment for the consultant’s travel and related expenses should be made directly to the third-party vendor whenever practical.
  • All payments must be recorded properly.

ACTIVITY NOT PERMITTED Consulting Arrangements:

  • A consulting arrangement that is not documented with a written consulting agreement.
  • Any consulting arrangement that is contrary to the regulations of the country where the HCP is licensed to practice.
  • Consulting agreement entered into with any HCP or Government Official in order to obtain or keep business or to obtain some improper advantage.
  • A consulting agreement which is for vague or unspecified services.

Decision Guide:

The following principles may help as a guide to making a decision on whether you are conducting yourself appropriately but if you are in any doubt you should consult the Sales and Marketing Director or the Managing Director.

Transparency:

Interaction with HCP must be transparent and comply with national laws. Hence notification of any interaction should be made to hospital management or local bodies.

Equivalence:

Where a HCP is engaged to perform a service, the remuneration must be commensurate with, and represent a fair market value, for the services rendered.

Separation:

Interaction with HCP MUST NOT be misused to influence purchasing decisions nor should such interaction be contingent upon sales transactions or use or recommendation of Henleys products.

Documentation:

There must be a written agreement or documentation supporting any interaction with HCP(s).

We use cookies to ensure that we give you the best experience on our website.