Bribery and Corruption defined
Bribery is designed to sway a person in the performance of his or her duties to act in a way that a reasonable person would in the circumstances consider to be dishonest. Bribes are not always a matter of payment of cash. Gifts, hospitality and entertainment can be considered as bribes if intended to influence a decision.
Where any person offers or gives a financial or other advantage or reward to another person which any reasonable person would consider to be improper - that is bribery.
Such as an offer or gift may be direct or indirect and are not restricted to activities on the Isle of Man, and particular attention should be given to the potential bribing of foreign public officials.
In the same way if any person accepts agrees to or requests a bribe or other inducement this is also bribery. Bribery is a serious offence and subject to severe criminal sanction. Peregrine is expected to have systems in place to prevent any person associated with the firm performing any act of bribery.
The Bribery Act 2013 of the Isle of Man and the UK Bribery Act 2010 provide severe penalties punishable by up to 10 years' imprisonment and/or an unlimited fine. If Peregrine, or any associated persons are found to have taken part in bribery or are found to lack adequate procedures to prevent or detect bribery, they too could face serious criminal sanctions.
It should be noted that in certain circumstances similar penalties could also be incurred for activities which transgress the Bribery Act 2010 (of the UK) and the Foreign Corrupt Practices Act of 1977 (of the USA) which could lead to extradition.
The following policy in relation to Bribery and Corruption applies strictly and equally to all employees, directors, agents, consultants, contractors and to any other persons or bodies connected with Peregrine within all their areas of practice, undertakings and functions.
Additionally these same policies apply to fiduciary clients via their corporate or trust structures to which financial services of any kind are supplied.
Peregrine has a zero tolerance policy to bribery in any form. Peregrine prohibits the offering, giving, solicitation or acceptance of any bribe whether in cash or in any other form:
This policy is not intended to prohibit the following practices provided they are appropriate and proportionate:
Peregrine expects its clients and those with whom it does business to have similar anti-bribery policies and procedures proportionate to their business activities.
Peregrine Corporate Services Limited is licensed by the Isle of Man Financial Services Authority.