ssued: 30th May 2025
Company: Barrow Mount Ltd
Company Registration Number: 15935241
Registered Address: 31–35 Kirby Street, London, EC1N 8TE
1. Statement
Barrow Mount is committed to the highest standards of ethical conduct and integrity in all of its business activities within the United Kingdom. We operate a zero-tolerance policy toward bribery, corruption, and unethical behaviour. This policy is designed to ensure compliance with the Bribery Act 2010 and applies to all employees, contractors, agents, and associated persons.
Senior management is committed to implementing and maintaining effective systems to prevent, detect and respond to bribery and unethical conduct.
2. Scope
This policy applies to all employees and officers of Barrow Mount Ltd, as well as any temporary workers, consultants, contractors, agents and suppliers acting for or on behalf of the company. Every individual is responsible for maintaining the highest standards of conduct.
Any breach may be treated as a serious disciplinary matter and may also result in legal action or termination of business relationships.
All suppliers and agents must acknowledge receipt of this policy, confirm their adherence to it, and reconfirm compliance on an annual basis.
3. Principles
Barrow Mount expects all employees and associated persons to operate with integrity, fairness and professionalism in all business dealings. The following conduct is expected:
- Behave honestly and fairly at all times
- Comply with legal and regulatory requirements
- Promote Barrow Mount’s reputation and conduct business with transparency
- Treat all stakeholders with respect
- Protect company assets and confidential information
The following behaviours are strictly prohibited:
- Using position or influence for personal gain
- Favouring individuals in recruitment or promotions based on bias
- Taking unfair advantage through dishonest or illegal means
- Misappropriation of company property or data
- Breaching this policy for commercial convenience
4. Bribery Act 2010
Barrow Mount complies fully with the Bribery Act 2010. A bribe is defined as offering, giving, receiving, or soliciting something of value with the intention of inducing or rewarding improper performance of a relevant function or activity.
Bribery of public officials, private individuals, or third parties is prohibited. It is also a criminal offence to fail to prevent bribery by a person associated with Barrow Mount.
4.1 What is prohibited
Employees and associated persons must not offer, request, or accept any bribe. This includes cash, gifts, favours, or hospitality intended to influence business outcomes. The prohibition extends to all transactions, whether in the UK or abroad, and includes indirect payments through agents or intermediaries.
4.2 Record keeping
All financial and operational records must be kept accurately. Payments, contracts, expenses, and any business transactions must be fully documented. Staff must also log all hospitality or gifts offered or received. Due diligence must be undertaken on new suppliers, partners, and representatives.
5. Corporate entertainment, gifts and promotional expenditure
Barrow Mount permits modest hospitality or gifts when used to build legitimate business relationships and when not intended to secure an unfair advantage. Such expenditure must be proportionate, reasonable and approved in advance where appropriate.
5.1 Charitable donations
Barrow Mount supports charitable causes. All donations are reviewed in line with due diligence and risk assessment. Employees may support fundraising but must ensure donations are not used to conceal improper payments.
6. Financial compliance and financial records
All financial statements and records must accurately reflect the company’s operations. It is prohibited to create false entries, hold undisclosed funds, or misrepresent financial information. Employees must never use company assets for unlawful purposes or falsify compliance reports or audit information.
7. Confidentiality
Staff and contractors must safeguard confidential information related to Barrow Mount, its clients, and candidates. This includes operating data, commercial agreements, personnel records and personal data. Information must only be disclosed when legally required or with appropriate authorisation.
8. Conflicts of interest
Employees must avoid any personal interest that conflicts with their duties. This includes undisclosed financial interests in suppliers or competitors, or the receipt of benefits due to their position at Barrow Mount.
All potential conflicts must be disclosed to a line manager. Any gifts or hospitality must also be declared.
9. Responsibilities
9.1 Management responsibility
Managers are accountable for ensuring compliance within their teams and for maintaining proper records. Management support is reinforced by audit processes to identify risks or weaknesses.
9.2 Employee responsibility
All employees must act lawfully and ethically, and uphold this policy in daily practice. Staff are expected to question and report any behaviour that appears improper.
10. Suspected breaches
Barrow Mount encourages an open reporting culture. Any suspected breach of this policy should be raised immediately with the managing director or via a confidential reporting route. Issues to report include:
- Suspected bribery or corruption
- Receipt or offer of improper gifts or incentives
- Unexplained financial irregularities
- Any act that brings Barrow Mount into disrepute
Employees who report concerns in good faith will be protected from retaliation. Victimisation of whistleblowers is a disciplinary offence. All reports will be fully investigated, and appropriate disciplinary or legal action taken if misconduct is found.