Anti-Bribery and Corruption Statement

Who This Statement Applies To

This commitment applies to Lycali’s directors, employees, workers, associates, contractors, volunteers and anyone acting on our behalf.

It applies across clinical services, referrals, recruitment, purchasing, partnerships, commissioning and tendering, in the UK and wherever anyone acts on Lycali’s behalf.

Our Ethical Standards

We will not offer, promise, give, request or accept a bribe, either directly or through another person. A bribe may include money, gifts, hospitality, services or another advantage intended to improperly influence a decision or reward improper conduct.

We do not permit facilitation payments, meaning unofficial payments intended to secure or speed up a routine action. Donations, sponsorship and referral arrangements must never be used to disguise bribery or secure an improper advantage.

We expect people acting on our behalf to uphold these standards and seek advice if they are unsure about a proposed arrangement or request.

Professional Judgement and Conflicts of Interest

Clinical recommendations must reflect the individual’s needs and the professional judgement of the practitioner. Commercial interests, personal relationships or incentives must not improperly influence recommendations or access to services.

Actual, potential or perceived conflicts of interest must be declared so they can be assessed and appropriately managed.

Recruitment, purchasing and contracting decisions must be fair, transparent and based on relevant, objective criteria.

Gifts and Hospitality

Gifts and hospitality must never influence, or appear to improperly influence, professional judgement or business decisions.

Any gift or hospitality offered or accepted must be reasonable, proportionate and transparent, and handled in accordance with Lycali’s internal approval and recording procedures.

• Cash and cash equivalents must not be offered or accepted as gifts.
• Gifts or hospitality intended to obtain preferential treatment or influence a procurement decision must be refused and reported.
• Where the purpose or appropriateness of an offer is unclear, advice must be sought before accepting or making the offer.

Preventing Bribery and Corruption

Lycali is committed to maintaining proportionate arrangements to identify and manage bribery risks. These include:

• Assessing risks associated with our activities and business relationships.
• Communicating our expectations and providing appropriate guidance to people working for or on behalf of Lycali.
• Undertaking relevant checks on contractors, suppliers and business partners.
• Maintaining financial controls and accurate records of transactions and relevant decisions.
• Recording and managing relevant interests, gifts and hospitality.
• Reviewing concerns and taking appropriate action where misconduct is identified.

Raising a Concern

Anyone who suspects bribery, corruption or an inappropriate request connected with Lycali is encouraged to raise their concern promptly.

Please email info@lycali.co.uk, marking your message “Private and confidential — ethics concern”. If the concern involves someone who would normally handle the enquiry, please indicate this so that alternative handling can be arranged.

Concerns will be handled sensitively, with information shared only where necessary to assess or investigate the matter or meet legal obligations.

Lycali does not tolerate retaliation against anyone who raises a genuine concern or refuses to participate in bribery, even where the concern is not subsequently substantiated.

This reporting route does not prevent anyone from contacting an appropriate external authority.

Accountability and Review

Lycali’s directors are responsible for overseeing this commitment. Breaches may result in disciplinary action, termination of contractual arrangements or referral to relevant authorities, as appropriate.

This statement summarises our commitment and supports our internal policies and procedures. It will be reviewed annually, or sooner where changes in our activities, legal requirements or identified risks require it.