Anti-corruption and bribery

We do not pay bribes and we do not take them. That is the whole position, and the rest of this page is about how we keep it true as the company grows.

What we will not do

• Offer, promise, give, ask for or accept anything of value meant to influence a decision improperly, in either direction.
• Make facilitation payments. These are small payments to speed up something the payer is entitled to anyway. They are common in some countries and they are illegal under United Kingdom law, with no exception for small amounts or local custom.
• Pay or accept a kickback, a commission or a referral fee that is not written down, agreed openly and disclosed to everyone it affects.
• Use a consultant, agent or intermediary as a way of doing something we could not do ourselves.

Gifts and hospitality

Hospitality is not bribery. Buying somebody lunch while you talk about their business is ordinary and lawful, and pretending otherwise makes a policy that nobody follows. What turns hospitality into a bribe is intent and proportion: whether it was meant to buy a decision, and whether it is the kind of thing you would be comfortable seeing written down.

Our rule is that test. If something we were offered or thinking of offering would look wrong written in an email to everyone involved, it does not happen. In practice that means ordinary hospitality at a meeting is fine, and anything beyond a modest value gets declined with an explanation rather than accepted and worried about.

We do not keep a gifts and hospitality register, because there would be nothing in it. Nobody at Sorteo Ltd has given or received a gift in connection with the business. If that changes, we will start keeping one rather than quietly widen the rule.

Why the risk in our business is low

Bribery risk concentrates in particular places: public sector procurement, work won through agents or intermediaries, operations in countries where corruption is common, industries with licences and permits to be granted, and long chains where nobody can see who was paid what.

None of those describes Bottle today. We sell software directly to privately owned businesses in the United Kingdom. We have no public sector customers and are not bidding for public contracts. We use no sales agents, resellers, introducers or intermediaries. We do not operate outside the United Kingdom and we have no dealings with public officials of any country. Our list prices are published. Where we agree a discount or a price of our own with a particular business, it is recorded against that account together with the reason for it, so a price that differs from the published one is written down rather than being a private arrangement between two people.

Who this applies to

It applies to anyone acting for or on behalf of Sorteo Ltd. Today that is one person, so the honest description is that it applies to the person who wrote it. When we take on staff, contractors, freelancers or anyone selling on our behalf, this page is part of what they agree to, and that is a condition of working with us rather than a document sent round for information.

Telling us about something

If you think somebody connected to Bottle has offered or accepted a bribe, or has been asked to, email hello@getbottle.app and say so. A person will read it and answer. You can ask us to keep your name out of it.

Nobody will suffer for raising a concern honestly, whether they turn out to be right or wrong. That includes losing work, losing a contract, or being treated differently afterwards. The law also protects people who report wrongdoing at work, and nothing here takes that away or asks anyone to come to us first. If you would rather speak to somebody independent, the charity Protect gives free confidential advice.

If you are not comfortable coming to us at all, bribery can be reported to the police, or to Action Fraud on 0300 123 2040.

Keeping this honest as we grow

This page describes a one-person company that sells directly, publishes its prices and has no agents. Several of those things will change. Taking on a reseller, selling into the public sector, or working outside the United Kingdom would each make the risk genuinely higher, and each would mean proper checks on who we are working with rather than a sentence on a website. We will rewrite this before any of that happens rather than afterwards.