Anti-Bribery and Corruption Statement
1. Policy Statement
APC Collective (a trading name of GalaProp Ltd) is committed to conducting all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships. We remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct in all jurisdictions.
2. Scope and Application
This policy applies to all persons working for us or on our behalf in any capacity, including directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.
3. What is Bribery?
A bribe is an inducement or reward offered, promised, or provided in order to gain any commercial, contractual, regulatory, or personal advantage.
Under the Bribery Act 2010, it is a criminal offence to:
Offer, promise, or give a bribe.
Request, agree to receive, or accept a bribe.
Bribe a foreign or domestic public official.
Fail to prevent bribery as a commercial organisation.
4. Public Sector and Local Authority Interactions
In our provision of Assessment of Professional Competence (APC) support packages, mentorship, and assessment services to public sector bodies and local authorities, we maintain the highest standards of transparency. We strictly prohibit the offering or acceptance of any incentives, gifts, or hospitality that could be perceived to improperly influence decision-making by public officials during procurement, contract execution, or service delivery.
5. Gifts and Hospitality
This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties. However, any gift or hospitality must:
Not be made with the intention of influencing a third party to obtain or retain business or a business advantage.
Comply with local laws.
Be given in the name of the company, not in an individual’s name.
Not include cash or a cash equivalent (such as gift certificates or vouchers).
Be appropriate in the circumstances and strictly proportionate to the business relationship.
Be given openly, not secretly.
6. Professional Integrity and Ethical Standards
As a business providing professional mentorship and training, we uphold the ethical standards expected within the surveying profession and by the Royal Institution of Chartered Surveyors (RICS). We expect all our candidates, mentors, and corporate clients to act with the same level of professional integrity, avoiding any conduct that could compromise the independence or fairness of the APC assessment process.
7. Raising Concerns
Anyone working on our behalf is encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries or concerns, these should be raised directly with the company directors at info@apccollective.co.uk.
8. Record Keeping
We keep financial records and maintain appropriate internal controls to evidence the business reason for making payments to third parties. All accounts, invoices, memoranda, and other documents and records relating to dealings with third parties, such as clients, suppliers, and business contacts, are prepared and maintained with strict accuracy and completeness. No accounts may be kept "off-book" to facilitate or conceal improper payments.
9. Policy Review
This statement will be reviewed regularly to ensure it remains relevant, effective, and compliant with all statutory obligations, reflecting our ongoing commitment to ethical business practices.