Star Refrigeration Ltd Anti-Bribery and Corruption Policy Statement


Our business is committed to promoting and maintaining the highest level of ethical standards and integrity in relation to all of its business activities. Every employee and individual acting on the company’s behalf is responsible for maintaining the company’s reputation and for conducting business honestly and professionally.  Therefore, the company has a zero tolerance policy towards bribery and corruption and is committed to acting fairly and with integrity in all of its business dealings and relationships and implementing and enforcing effective systems to counter bribery.

Legal Obligations

Bribery is illegal under the Bribery Act 2010 and applies to the company’s conduct both in the UK and abroad. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. 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.  The company does not allow kickbacks nor facilitation payments of any nature in return for a business favour or advantage. If employees are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from line management and our full Anti-Bribery Policy and guidance.


Responsibilities, Training & Communication

The prevention, detection and reporting of bribery and corruption is the responsibility of all those working for the company. Employees are required to avoid any activity which might lead to, or suggest a breach of the policy and seek advice as needed over any concerns.


The company have issued an anti-bribery and corruption policy outlining the company’s position on preventing and prohibiting bribery and corruption including guidance on gifts and corporate hospitality.  This policy applies to all employees and they are required to familiarise themselves with and comply with the policy.  The company also provide relevant anti-bribery and corruption training to employees where their role requires a more in depth knowledge of compliance with the Bribery Act.

The success of the company’s anti-bribery and corruption measures depends on all employees, and those acting for the company, playing their part in helping prevent bribery. Therefore, all employees and others acting for, or on behalf of, the company are encouraged to report any suspected bribery in accordance with the procedures set out in the policy. The company will support any individuals who make such a report in good faith.


Updated September 2021