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Anti-Bribery & Construction Sector Policy

Purpose

The purpose of this Policy is to support the mission of the Construction Equipment Association (CEA) and its members in maintaining the highest standards of integrity and transparency in the construction sector. The CEA is committed to ensuring that bribery and corruption have no place in construction related business activities, including those of its members, contractors, subcontractors, suppliers and other associated parties.

Scope

This policy applies to:

  • All members of the CEA, and their directors, officers and employees.
  • Contractors, subcontractors, suppliers, consultants and agents acting for or on behalf of a members in construction related activities.
  • Joint ventures, partnerships or other entities in which a member participates, where construction activities are involved.
  • All jurisdictions in which members operate (including both UK and overseas).
Legal framework
  • The UK Bribery Act 2010 applies to UK based organisations and to UK operations abroad; it prohibits offering, promising or giving a bribe, requesting or receiving a bribe, and the corporate offence of failing to prevent bribery by persons acting on behalf of an organisation.
  • Members should also consider relevant legislation in jurisdictions in which they operate (including anti‑corruption statutes, economic crime legislation, etc.).
  • This Policy aligns with the Government guidance on anti‑bribery policies.
Definitions
  • Bribery: Offering, giving, promising, requesting or receiving a financial or other advantage in order to induce or reward improper performance of a relevant function or activity.
  • Corruption: The abuse of entrusted power for private gain.
  • Facilitation Payment: A small payment made to expedite or secure the performance of a routine governmental action. These are prohibited.
  • Associated Persons: Agents, contractors, subcontractors, suppliers, joint venture partners or other third parties acting for or on behalf of a members.
  • Improper Performance: Performance of a relevant function or activity which is in breach of an expectation of good faith, impartiality or a position of trust.
Policy statement

The CEA and its members adopt a zero tolerance approach to bribery and corruption in all construction sector activity. All personnel, contractors and associated persons must act honestly, openly and with integrity. Any breach of this policy may lead to disciplinary action, contractual termination, and potential criminal liability.

Gifts, hospitality, donations and sponsorship
  • Members may only give or receive modest gifts or hospitality that are reasonable, proportionate, transparent and for a legitimate business purpose.
  • Gifts or hospitality must never be offered or accepted with the intention of influencing a business outcome or improperly gaining an advantage.
  • Donations or sponsorships must not be used as a substitute for a prohibited payment or favour.
  • All gifts, hospitality, sponsorships must be recorded in an approved register by the member.
  • Facilitation payments are prohibited.
Risk assessment & due diligence
  • Members must undertake periodic risk assessments regarding bribery and corruption in their construction activities, including analysing geographic, sectoral and supply chain risks.
  • Due diligence must be carried out on contractors, subcontractors, suppliers, agents and other associated persons before engagement, especially in high risk jurisdictions or high value transactions.
  • Anti‑bribery obligations should be reflected in contracts and procurement terms with associated persons.
Financial & commercial controls
  • Members must maintain accurate, complete and transparent records of payments, contracts, expenses and transactions associated with construction activities.
  • No “off‑book” or undisclosed accounts may be maintained for any purpose.
  • All construction related transactions must comply with the members internal control procedures and the contractual terms with the CEA or clients.
Training & communication
  • The CEA will work with members to provide (or recommend) appropriate training on anti‑bribery and corruption for staff, contractors and associated persons.
  • Members must ensure that relevant personnel (including procurement, site management, supply chain, and senior management) receive training at induction and periodically thereafter.
  • The Policy must be communicated clearly to all employees, contractors, subcontractors, suppliers and agents.
Reporting, whistleblowing & investigation
  • Members must establish a mechanism (confidential and if possible anonymised) for employees and third parties to report concerns or suspicions of bribery or corruption.
  • Reports shall be promptly investigated by the member (or by the CEA if agreed) and appropriate remedial action taken, including notifying law enforcement or regulatory bodies if required.
  • Retaliation against individuals who report concerns in good faith is strictly prohibited.
Disciplinary measures & sanctions
  • Breach of this Policy may lead to disciplinary action for employees (up to and including termination) or termination of business relationships with contractors, suppliers or agents.
  • Members may be required to notify the CEA of serious breaches.
  • Criminal liabilities (including fines and imprisonment) may apply for individuals and organisations under the UK Bribery Act.
Monitoring, review & continuous improvement
  • The CEA will review this policy annually (or sooner if legal or operational changes require) and communicate any changes to members.
  • Members are expected to monitor compliance, perform periodic ethical audits or reviews, and update their procedures as necessary.
  • Lessons learned from incidents, investigations or near misses should be reviewed and incorporated into policy updates or training.
Roles & responsibilities
  • Board of Directors: Provides oversight and leadership, approves this Policy and allocates resources.
  • Members: Responsible for embedding and enforcing this Policy within their organisation and supply chain.
  • Employees, Contractors, Suppliers and Agents: Must adhere to this Policy, complete required training and promptly report concerns.
  • Compliance Officer: Maintains records, arranges training, monitors implementation and reports to senior management.
Scope of application & review

This policy is applicable from the effective date and remains binding until superseded. It may be amended at any time by the CEA subject to approval by its Board, and members will be notified promptly.