Wright Wiseman Stewart Capital Partners Ltd values its reputation for ethical behaviour and for financial probity and reliability. It recognises that over and above the commission of any crime, any involvement in bribery will also reflect adversely on its image and reputation. Its aim therefore is to limit its exposure to bribery by:
Wright Wiseman Stewart Capital Partners Ltd prohibits:
the offering, the giving, the solicitation or the acceptance of any bribe, whether cash or other inducement to or from any person or company, wherever they are situated and whether they are a public official or body or private person or company by any individual consultant, agent or other person or body acting on Wright Wiseman Stewart Capital Partners Ltd’s behalf in order to
gain any commercial, contractual or regulatory advantage for Wright Wiseman Stewart Capital Partners Ltd in a way which is unethical or in order to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual.
Wright Wiseman Stewart Capital Partners Ltd recognises that market practice varies across the territories in which it does business and what is normal and acceptable in one place may not be in another. This policy prohibits any inducement which results in a personal gain or advantage to the recipient or any person or body associated with them, and which is intended to influence them to take action which may not be solely in the interests of the firm or of the person or body employing or contracting with them or whom they represent.
This policy is not meant to prohibit the following practices providing they are customary in a particular market, are proportionate and are properly recorded:
Inevitably, decisions as to what is acceptable may not always be easy. If anyone is in doubt as to whether a potential act constitutes bribery, the matter should be referred to the local senior manager with responsibility for this policy before proceeding. If necessary, guidance should also be sought from the Compliance Officer.
Consultants and Principles Responsibility within Wright Wiseman Stewart Capital Partners Ltd
The prevention, detection and reporting of bribery is the responsibility of all consultants throughout Wright Wiseman Stewart Capital Partners Ltd. Suitable channels of communication by which consultants or others can report confidentially any suspicion of bribery will be maintained via the Anti-Corruption Reporting procedures.
Useful resource: www.transparency.org.uk for the Transparency Index A fuller Policy and Procedures outlining all the Principles of the Act can be requested from the Compliance Officer of Sturgeon Ventures LLP, of whom Wright Wiseman Stewart Capital Partners Ltd is an Appointed Representative firm, by emailing firstname.lastname@example.org
Wright Wiseman Stewart Capital Partners Limited is an appointed representative of Sturgeon Ventures LLP (FRN 452811).
Sturgeon Ventures is authorised and regulated by the Financial Conduct Authority (FCA).
Wright Wiseman Stewart Capital Partners Limited Registered in England Company No: 12166761
Registered Address: Devonshire House, 1 Devonshire Street, London, W1W 5DR, United Kingdom
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