Anti-bribery and corruption statement

The Bribery Act 2010 (“the Act”) is effective from 1st July 2011. The Act repeals and consolidates previous corruption legislation. In addition to the established criminal offences of giving and receiving a bribe, this Act places specific responsibility on organisations to have in place adequate procedures to prevent bribery. Should bribery occur, as well as the offences on the part of the individuals concerned, firms will also be liable for the corporate offence of failing to prevent bribery unless they can demonstrate that adequate preventative measures were in place.

Bribery occurs where there is intent to give someone a financial or other advantage to encourage that person to perform their functions or activities improperly or to reward that person for having already done so. It is an inducement for an action which is illegal, unethical or a breach of trust, and can take the form of gifts, loans, fees, rewards or other privileges.



The Act applies to firms that do business in the UK (whether incorporated in the UK or not), doing business anywhere in the world. An offence under Sections 1, 2 and 6 of the Act apply to acts committed overseas (where the act or omission would have been an offence if done or made in the UK) and the person has a “close connection” with the UK. Those with a close connection are defined to include British citizens, individuals ordinarily resident in any part of the UK and bodies incorporated under UK law.

It will be a defence (under section 7 (2)) for a commercial firm to prove that it had in place adequate procedures designed to prevent persons associated with it undertaking offences under the Act. All directors and employees are required to comply with this Anti-bribery Policy.



The Act’s statutory offences are as follows:

Offences of bribing another person “The active offence” (Section 1)

It is an offence to offer, promise or give a financial or other advantage (“bribe”) to another person where it is intended to induce the improper performance of a relevant function or activity or to reward for such an improper performance.

Maximum penalty: 10 years and/or unlimited fine.

Offences relating to being bribed “The passive offence” (Section 2)

It is an offence for a person to request, agree to receive or accept a bribe. It does not matter whether the recipient of the bribe receives it directly or through a third party.

Maximum penalty: 10 years imprisonment and/or unlimited fine.

Bribery of foreign public officials (Section 6)

It is an offence to bribe a foreign public official (“FPO”), where it is intended to influence the FPO in the performance of his or her official functions in order to obtain or retain business or an advantage.

Maximum penalty: 10 years imprisonment and/or unlimited fine.

Failure of commercial firms to prevent bribery (Section 7)

It is an offence for a commercial firm (including a body corporate, partnerships conducting business in the UK) to fail to prevent bribery by persons performing services on its behalf (“associate persons”). Such an offence will arise where a person associated with the firm bribes another person intending to obtain or retain business for the firm or to obtain or retain an advantage in the conduct of business for the firm. Persons "associated" with the firm could include employees, agents, contractors and joint-venture arrangements and subsidiaries. However, a subsidiary will only be an associated person if the bribe obtained is intended to benefit the Parent directly.

Penalty: unlimited fine.

Offences under sections 1, 2, and 6 by bodies corporate (Section 14)

A senior officer of a commercial firm will be personally liable if the offence under section 1,2 and 6 has been committed with his/her consent or connivance which in the absence of a technical definition shall be taken to mean participation, involvement, responsibility or collusion.
Maximum penalty: 10 years imprisonment and/or unlimited fine.



The Ministry of Justice has issued Guidance that sets out the six principles intended to assist a firm in ensuring that the adequate procedures are proportionate to the nature, scale and complexity of a firm and to assist a firm in complying


Top level commitment

Pioneer is committed to deterring, preventing and detecting bribery in the following ways:

  • There is a zero tolerance policy towards bribery and such acts would be regarded as gross misconduct or breach of contract. Staff may also face legal action by the Serious Fraud Office (“SFO”) if they act in breach of this Policy (see penalties under the offences outlined above).
  • The giving or receiving of improper inducements, of any value, is strictly prohibited.
  • Facilitation payments must not be made or charged.
  • The directors have taken reasonable steps to ensure that all staff are aware of this Policy in respect of corruption and that it works along-side existing policies which is considered to be the anti-corruption framework of Pioneer.
  • Risk assessment & proportionality

A periodic risk assessment will be carried out to ensure that Pioneer’s procedures are proportionate to the bribery risks the firm or its associated persons face, and to the nature, scale and complexity of the business. Pioneer’s risk has been assessed as generally low because it does not operate in a risky business sector and is a very small firm. Most of Pioneer’s third party associated persons are UK suppliers of standard goods or services to Pioneer which are considered to represent a very low to zero risk. Many of these are Financial Conduct Authority (“FCA”) regulated firms. Also, the jurisdiction is mainly UK only. Some third parties are given capital for onward investment including in offshore markets.

Pioneer’s procedures have been determined with these risks in mind, including the actions we are taking for particular third parties. These risks are reconsidered on an informal basis at the time for new lines of business and new business relationships.


Due diligence

Due diligence is carried out to help prevent associated persons from bribing on behalf of the Pioneer. This includes due diligence on directors, employees, agents and other third parties as determined by our risk assessment.


Communication & training

Pioneer has a zero-tolerance approach to bribery and corruption and this is communicated to all third parties that provide a service to Pioneer at the outset of the business relationship. To enhance awareness and help deter bribery Pioneer has the following arrangements in place:

  • All directors and employees of Pioneer, together with third parties receive training or training material on Pioneer’s Anti-bribery Policy and procedures.
  • Pioneer may obtain a written acknowledgement from these persons of the need to comply with this Policy.
  • When contracts are renewed an anti-bribery clause is to be added.
  • Other third parties where there is a lower risk of bribery will receive notification of the Anti-bribery Policy with a request to comply.
  • Future associated persons will be treated similarly at the time of appointment.
  • As a deterrent to others, Pioneer’s Anti-bribery Policy is published on its website.
  • Monitoring & review

Pioneer will monitor and evaluate the effectiveness of its bribery prevention procedures as part of the compliance monitoring process
A formal update and review of the risk assessment is carried out every 2-3 years in conjunction with the existing fraud risk assessment process.
Changes to business partners and lines of business are considered in relation to bribery risks, as they occur.
Gifts and hospitality below £100 given or received by employees must be notified to Compliance and anything over £100 must be notified and approved by Compliance. Each notification must be accompanied by a statement that they do not constitute any form of inducement to encourage improper conduct and do not create a conflict of interest.

Business meals are exempt from the notification requirement.

Cash of any value cannot be given or accepted.

There is a dual control approval process for all company payments which ensures they are for valid purposes.


Raising a concern

Should members of staff (or any associated persons) be approached with a bribe or wish to report any concerns or allegations they should report the matter confidentially.

The Following is a list of possible “red flags” which must be reported promptly if encountered (not limited to):

  • the third party has a reputation of engaging in improper business practices;
  • the third party insists on receiving a commission or fee payment before committing to sign up to contact;
  • the third party requests payment in cash or refuses to sign up a formal commission or fee agreement;
  • the third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business;
  • the third party requests an unexpected additional fee to facilitate a service; and
  • staff are offered an unusually generous gift or offered lavish hospitality by the third party.
  • Responsibilities of the MLRO

In relation to reports of bribes or suspicion reports made by a member of staff, the MLRO shall be responsible for analysing the basis of these reports. Where a decision has been made not to contact the SFO, a record should be kept internally. The SFO encourages self-reporting by firms.

If you have been a victim of fraud, please call Action Fraud on 0300 123 2040.

Pioneer also considers the obligation to report any suspicions to the National Crime Agency (“NCA”). The benefit gained by virtue of a payment of a bribe will be tainted by the act of illegality through which it was obtained and is likely to constitute criminal property under the Proceeds of Crime Act 2002 (“POCA”), the main UK anti-money laundering legislation. Under POCA, criminal property is property that represents a benefit from criminal conduct. A person who did not commit an underlying offence can still commit a money laundering offence where he/she holds property that represents a benefit under that offence. Therefore, it does not matter who engaged in the criminal conduct; where criminal property is generated a money laundering offence will be committed.

Pioneer’s MLRO will determine whether or not to report the matter to the NCA.

Team Pioneer

Nulli Secundus