Anti-Bribery policy

UK Bribery Act

As a mutual insurer for companies within the transport sector ITIC and its Managers, Thomas Miller/ ITIM Co Ltd, set great store by equity between Members and probity when dealing on their behalf. In support of our commitment to maintaining the highest possible standards of business practice we hold a 'zero-tolerance' stance towards bribery. Bribery is illegal and as such has no place in our organisation.

Our Policy

In accordance with the Bribery Act 2010, ITIC prohibits absolutely the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement, regardless of size:

  • to or from any person or company, wherever they are situated and whether they are a public official or body or private person or company;
  • by any individual employee, agent or other person or body acting on behalf of ITIC;
  • in order to gain any commercial, contractual or regulatory advantage for ITIC in a way which is illegal or unethical;
  • or in order to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual.

Interpreting the policy

It is not the intention of the policy to prevent the following activities, particularly in relation to our international role as an insurer and claims handler

  • Normal and appropriate hospitality.
  • The giving and receiving of ceremonial gifts.

Such hospitality or gifts must be in moderation and not place any expectation on the recipient to reciprocate either in like or by performing, or failing to perform, any other task in return.

If there is any doubt as to whether an action might constitute bribery the matter should be referred to a director of the management team of ITIC, Thomas Miller/ITIM Co Ltd , for a decision.

Preventing and reporting bribery

All management staff working on behalf of the ITIC have a responsibility to prevent, detect and report bribery. We provide appropriate guidance to our staff in fulfilling this duty.

Should you hold any suspicion of bribery or attempted bribery committed by or against an employee, agent or other party acting on behalf of ITIC, it must be reported immediately to a director of the management team.

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