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Anti-bribery
The Firms Website Statement on its Anti Bribery Policy.
Milestone Capital Partners LLP are committed to ensuring that the firm, its associates, staff and agents comply with the requirements of the Bribery Act 2010. It is committed to conducting its business fairly, honestly and openly, and has a zero tolerance towards bribery. It has implemented a risk based approach to identify areas where it may be at risk to bribery and has put in place systems and procedures to reduce this risk. It will not deal with firms’ individuals or other entities that refuse to give the same commitment. The firm has implemented a number of procedures which are monitored for effectiveness on a regular basis which are intended to prevent the firm, its staff or agents being involved in bribery. These are reviewed regularly to ensure they remain current and robust.
How Milestone Capital Partners LLP aims to prevent bribery by the firm its employees or agents:
- Senior Management overview of the processes.
- Initial risk assessments for existing and new business opportunities and agents, plus annual risk assessment reviews of the firms risk and mitigation processes.
- Thorough due diligence of existing and prospective associated persons
- A Gifts policy as detailed in the policies manual requiring all staff and agents to obtain permission from senior management before making or accepting gifts, benefits or donations such as hospitality over £250.
- Terms and conditions and disciplinary actions stipulated in employment contracts or engagement letters requiring adherence to the policies and procedures.
- Senior management governance of all business relationships with other associated persons both pre and post contractual agreements.
- Financial controls requiring the approval by senior management for all non petty cash expenditure.
- Transparency of transactions and the disclosure of information.
- A conflicts of interest policy as detailed in the policies manual.
- A whistleblowing policy as detailed in the policies manual which allows staff to report suspicions or concerns to the relevant authority in the event that the firm does not deal with the concern satisfactory.
- Initial and annual declarations by staff and agents to say they have read, understood and will abide by the firms policies.
- Training of staff to ensure they are aware of the firms policies.
- Regular monitoring of the firms systems and controls to ensure adherence.