Dunelm takes a zero tolerance approach to bribery, corruption, fraud and tax evasion.
The Group pays corporation tax on its operations in the United Kingdom and Jersey and does not operate in any tax havens, or use any tax avoidance schemes.
Our Anti-Corruption and Anti-Bribery Policy and our Tax Strategy are available on our website https://corporate.dunelm.com.
The main areas of potential risk in Dunelm's organisation are:
- A colleague accepting a bribe or some other personal advantage in return for awarding a contract
- A supplier acting on Dunelm's behalf offering or accepting a bribe or other personal advantage
- A Dunelm colleague facilitating tax evasion by a third party, for example by making an "off book" payment to enable a third party to avoid tax
The procedures in place to ensure compliance with the Bribery Act 2011 and other relevant legislation are set out below:
- Anti-corruption and anti-bribery policy implemented – which also covers fraud and tax evasion
- Formal procedure implemented for signing off and logging gifts and hospitality accepted by colleagues
- Executive Board members, Senior colleagues, all members of the commercial team and any individuals with authority to place significant contract orders have received anti-bribery training and complete an annual refresher
- All Senior colleagues sign a declaration of compliance and conflicts of interest statement annually
- Standard terms and conditions for suppliers include a Bribery Act / tax evasion clause
- Specific training has been carried out for suppliers and agents in high risk territories
- All payments to third parties must be supported by a valid invoice and segregated duties are in place in the finance team; commercial checks made on all new suppliers; policy on engagement of contractors under review
- Our Whistleblowing Policy refers specifically to the Bribery Act, fraud and tax evasion and an externally hosted independent helpline is in place
- Standing agenda item for the Audit and Risk Committee
Measuring our impact
- % of internal training completed – 100%
This report was reviewed and signed by order of the Board on 12th September 2018.
Nick Wilkinson Chief Executive Officer