Nationwide Energy Consultants Utilities Ltd operates a zero-tolerance approach to bribery, corruption and improper business practices.
Nationwide Energy Consultants Utilities Ltd is committed to conducting business honestly, fairly, transparently and with integrity.
We operate a zero-tolerance approach to bribery, corruption and improper business practices. We will not offer, give, request, accept or receive any bribe, kickback, improper payment, secret commission, undisclosed inducement or other improper advantage, whether directly or indirectly.
This policy applies to all employees, directors, consultants, contractors, agents, introducers, suppliers, partners, and any other person or organisation acting for or on behalf of Nationwide Energy Consultants Utilities Ltd.
Bribery is a criminal offence under the Bribery Act 2010. It can expose both individuals and the company to serious consequences, including criminal prosecution, fines, reputational damage, loss of supplier relationships and loss of customer trust.
The purpose of this policy is to:
This policy applies to:
For the purpose of this policy, these people may be referred to as “associated persons”.
Bribery means offering, promising, giving, requesting, agreeing to receive or accepting something of value with the intention of improperly influencing a decision or gaining a business advantage.
A bribe does not have to be cash. It can include:
Bribery can occur whether the advantage is offered directly or indirectly through another person, business, agent, consultant or intermediary.
The following examples would be unacceptable:
Nationwide Energy recognises that modest and reasonable gifts or hospitality may form part of normal business relationships. However, gifts and hospitality must never be used to influence business decisions improperly.
Acceptable gifts or hospitality may include:
Gifts or hospitality must not be accepted or offered if:
Approval and recording
Any gift or hospitality with a value above £50 must be declared to a director or line manager and recorded in the company’s Gifts and Hospitality Register.
Any gift or hospitality with a value above £100 must receive prior approval from a director before it is accepted or offered.
Cash gifts, vouchers, personal payments or secret incentives must never be accepted.
Nationwide Energy may receive commission or commercial payments from suppliers, partners or service providers as part of its business model. These arrangements must be handled transparently, fairly and in line with applicable law, supplier agreements and customer expectations.
All commission arrangements must be:
Employees must not accept personal commissions, gifts, payments or benefits from suppliers, customers, introducers or third parties unless expressly authorised by the company.
Nationwide Energy may work with introducers, referral partners, suppliers, consultants or other third parties. These relationships can create bribery and corruption risks if not properly controlled.
Before entering into any introducer or referral arrangement, Nationwide Energy should consider:
All introducer, referral or third-party payments must be approved and recorded. No payment should be made where there is a suspicion that it may be used as a bribe or improper inducement.
A conflict of interest may arise where personal interests, relationships or financial incentives could affect, or appear to affect, an employee’s judgement.
Examples include:
All actual or potential conflicts of interest must be declared to a director as soon as they are identified.
Facilitation payments are unofficial payments made to speed up or secure a routine action, such as processing paperwork, releasing information, completing an administrative task or progressing a service request.
Nationwide Energy does not permit facilitation payments.
This applies even where the payment is small or where it is described as a “fee”, “admin payment”, “gesture”, “thank you” or “expedite payment”.
If an employee is asked to make a facilitation payment, they must refuse and report the request to a director.
Nationwide Energy may support local events, trade bodies, industry initiatives, charity events or hospitality sector activities where there is a genuine and lawful purpose.
However, donations or sponsorship must never be used to improperly influence a customer, supplier, pub company, brewery, trade body, public official or business partner.
All donations and sponsorships must be:
Political donations must not be made on behalf of Nationwide Energy unless expressly approved by the board and confirmed as lawful.
Extra care must be taken when dealing with public officials, regulators, government bodies, local authorities or public sector organisations.
No gift, payment, hospitality or benefit should be offered to a public official if it could be seen as an attempt to influence them improperly.
This includes dealings with regulators, ombudsman services, government departments, local authorities or public bodies.
Any proposed gift, hospitality, sponsorship, donation or payment involving a public official must be approved by a director in advance.
Nationwide Energy’s reputation is built on trust, transparency and acting in the customer’s best interests.
Employees must ensure that any recommendation, contract placement, renewal, supplier contact or additional service is based on genuine customer suitability and not improper influence.
This means:
Nationwide Energy must keep accurate records of:
Records must be complete, accurate and not misleading.
Employees must not create false records, hide payments, split payments to avoid approval limits, or describe payments inaccurately.
Employees and associated persons must report any concern, suspicion or request relating to bribery or corruption as soon as possible.
This includes:
Concerns should be reported to a director or senior manager.
Reports will be treated seriously and, where possible, confidentially.
Nationwide Energy will not tolerate victimisation or retaliation against anyone who raises a genuine concern in good faith.
Directors and senior management are responsible for:
Employees and associated persons are responsible for:
Nationwide Energy will communicate this policy to relevant employees and associated persons.
Training or guidance may be provided where appropriate, particularly for employees involved in:
A breach of this policy may result in disciplinary action, up to and including dismissal.
For contractors, consultants, agents, introducers or third parties, a breach may result in termination of the business relationship.
Serious breaches may also be reported to the police, regulators or other relevant authorities.
Nationwide Energy will review this policy periodically to ensure it remains appropriate and effective.
The company may also review:
This policy should be reviewed at least every 12 months, or sooner if there is a material change in the business, law or regulatory environment.
Any questions about this policy should be referred to a director or senior manager.
Where there is uncertainty, employees should always seek guidance before accepting or offering gifts, hospitality, payments, incentives or other benefits.
Approved by Nationwide Energy Consultants Utilities Ltd (Company Number 04273703) · Policy Owner: Directors / Senior Management · Effective 22 May 2026 · Next review 22 May 2028.