Policy Code: LHPOL0006Date first issued: 25 August 2023Date last updated: 25 August 2023
Version no: 1.0Document owner: Andrew SatherleyDate of next review: 25 August 2024




Anti-Bribery and Corruption



This anti-bribery policy exists to set out the responsibilities of Lightning Health and those who work for us or on our behalf in any capacity in regard to observing and upholding our zero-tolerance position on bribery and corruption.


It also exists to act as a source of information and guidance for those working for and on behalf of Lightning Health. It helps them recognise and deal with bribery and corruption issues, as well as understand their responsibilities.


Lightning Health is committed to conducting business in an ethical and honest manner and is committed to implementing and enforcing systems that ensure bribery is prevented. Lightning Health has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships.


Lightning Health will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, in regard to our conduct both at home and abroad.


Lightning Health recognises that bribery and corruption are punishable by up to ten years of imprisonment and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business and take our legal responsibilities seriously.



  1. SCOPE

This anti-bribery policy applies to all employees (whether temporary, fixed term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties such as research participants, suppliers and clients), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK). The policy also applies to Officers, Trustees, Board, and/or Committee members at any level.


In the context of this policy, third-party refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.


Any arrangements our company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to anti-bribery and corruption.




Andrew Satherley – Compliance ManagerResponsible for monitoring the effectiveness of this policy

Maintains the Gifts and Hospitality Register



5.1. Definition of bribery

Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence a person to act improperly in the performance of their functions or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage. A bribe refers to a financial or other any inducement or reward for any action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.


Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.


Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the company’s compliance manager (Andrew Satherley) before agreeing to accept.

5.2. What is and what is NOT acceptable

This section of the policy refers to four areas: Gifts and hospitality; Facilitation payments; Political contributions; Charitable contributions.


5.2.1. Gifts and hospitality

Whilst Lightning Health does not permit gifts being given to clients, it permits normal and appropriate gestures of hospitality and goodwill given to/received from third parties and suppliers so long as the giving or receiving of gifts meets the following requirements:

  • It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits
  • It is not made with the suggestion that a return favour is expected
  • It is in compliance with local law
  • It is given in the name of the company, not in an individual’s name
  • It does not include cash or a cash equivalent (e.g. a voucher or gift certificate)
  • It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift
  • It is given/received openly, not secretly
  • It is not selectively given to a key, influential person, clearly with the intention of directly influencing them
  • It is not above £100, as pre-determined by the company’s compliance manager
  • It is not offer to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s compliance manager


Where patients and/or patient advocacy groups have participated in market research, Lightning Health allows customary honorarium payment by way of monetary payment or voucher. Any payment must be inline with the most appropriate guidelines – BHBIA/EphMRA.


Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted so long as it is declared to the compliance manager, who will assess the circumstances.


Lightning Health recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each.


As good practice, gifts given and received should always be disclosed to the compliance manager. Gifts from suppliers should always be disclosed. It is the duty of the compliance manager to maintain the Gifts and Hospitality Register.


The intention behind a gift being given/received should always be considered. The test to be applied is whether in all the circumstances the gift, hospitality or payment is reasonable and justifiable. If there is any uncertainty, the advice of the compliance manager should be sought.


5.2.2. Facilitation payments and kickbacks

Lightning Health does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognise that they tend to be small unofficial payments also known as “back-handers” made by low level officials with the intention of securing or speeding up the performance of a certain duty or action.


Lightning Health does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage.

You must avoid any activity that might lead to a facilitation payment or kickback being made or accepted by us or on our behalf, or that might suggest that such a payment will be made or accepted. If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with the compliance manager.


  • 2.3. Political contributions

Lightning Health will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage.


5.2.4. Charitable contributions

Lightning Health accepts (and indeed encourages) the act of donating to charities or patient advocacy groups – whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees to disclose upon request all charitable contributions it makes.


Employees must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery. We will ensure that all charitable donations made are legal and ethical under local laws and practices, and that donations are not offered/made without the approval of the compliance manager.

5.3. Employee responsibilities

As an employee of Lightning Health, you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other anti-bribery and corruption information you are given.


All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy. Employees must also not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.


If you have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, you must notify the compliance manager.


If any employee breaches this policy, they will face disciplinary action in accordance with the Disciplinary procedure detailed in the Company handbook. Lightning Health has the right to terminate a contractual relationship with immediate effect any non-employee if they breach this anti-bribery policy.


5.4. What happens if I need to raise a concern?

This section of the policy covers three areas:

  • How to raise a concern.
  • What to do if you are a victim of bribery or corruption.

5.4.1. How to raise a concern

If you suspect that there is an instance of bribery or corrupt activities or other breach of this policy has occurred or may occur in relation to Lightning Health, you are encouraged to raise your concerns at as early a stage as possible. If you are uncertain about whether a certain action or behaviour can be considered bribery or corruption, you should speak to the compliance manager, (Andrew Satherley, asatherley@lightning.health). If they cannot be contacted, you should raise your concerns with your line manager or another Director of Lightning Health.

5.4.2. What to do if you are a victim of bribery or corruption

You must tell your compliance manager as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity.


5.4.3. Protection

If you have a concern relating to potential act(s) of bribery or corruption you should inform your line manager or the compliance manager immediately. Lightning Health will support anyone who raises genuine concerns in good faith under this policy. All matters will be treated with the strictest confidentiality.

5.5. Training and communication

Lightning Health will provide training on this policy as part of the induction process for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy, and will be asked annually to formally accept that they will comply with this policy.


Lightning Health’s anti-bribery and corruption policy and zero-tolerance attitude will be communicated to all suppliers, contractors, business partners, and any third-parties at the outset of business relations, and as appropriate thereafter.

5.6. Record keeping

Lightning Health is required to keep detailed and accurate financial records and have appropriate internal controls in place to act as evidence for all payments made. You must declare to the compliance manager a record of the amount and reason for hospitality or gifts accepted and given and understand that gifts and acts of hospitality are subject to managerial review.


You must also submit all expense claims relating to hospitality, gifts or payments to third parties in accordance with our Travel and Expenses policy – LHPOL0004, and record the reason for expenditure.


All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.

5.7. Monitoring and reviewing

Lightning Health’s compliance manager is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness.


Internal control systems and procedures designed to prevent bribery and corruption are subject to regular internal audits to ensure that they are effective in practice.


Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the compliance manager. This policy does not form part of an employee’s contract of employment and Lightning Health may amend it at any time so to improve its effectiveness at combatting bribery and corruption.



Company handbookCan be found on company’s HR software system
Gifts and Hospitality RegisterMaintained by Compliance manager
PolicyTravel and Expenses – LHPOL0004






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