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Anti-Bribery and Corruption Policy



  • 1.1 PURPOSE 
  • 1.4 SCOPE 


1.1. Purpose
The purpose of this policy is to establish controls to ensure compliance with all applicable anti-bribery and corruption regulations, and to ensure that the Blue Saffron Ltd. t/a Dangan Group’s business is conducted in a socially responsible manner.

1.2. Policy statement
Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal or a breach of trust. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

Irish law criminalises bribery and corruption.
The Criminal Justice (Corruption Offences) Act 2018 (the 2018 Act) is the key legislation governing bribery and corruption in Ireland. The 2018 Act makes it an offence for any person to corruptly offer, give to, or accept from a person, a "gift, consideration or advantage" as an inducement to, reward for, or on account of any person doing an act in relation to their office, employment, position or business.

Irish law does not distinguish facilitation payments from corrupt payments, and therefore the payment of a "facilitation payment" will be an offence if it falls within the criteria for a corrupt payment.

The principal offenses under the 2018 Act are:

  • active and passive corruption;
  • active and passive trading in influence;
  • corruption in relation to office, employment, position or business;
  • giving a gift, consideration or advantage that may be used to facilitate an offense;
  • creating or using a false document;
  • intimidation.

1.3. Legal consequences
Most offences carry a penalty of 10 years imprisonment and/or an unlimited fine upon conviction. Irish corruption law has a global reach and is applicable to Irish Nationals, Irish Companies and persons ordinarily resident in Ireland when abroad.

Ireland is very committed to ensuring that bribes to officials either at home or abroad are treated as criminal offences. It is also committed to raising awareness of its obligations under international treaties or conventions so that a level playing field can be created for all companies operating internationally.

Companies convicted of bribery offenses may face debarment from public procurement contracts under the EU Public Procurement Directive.


1.4. Scope
It is Blue Saffron Ltd. t/a Dangan Group’s policy to conduct all of our business in an honest and ethical manner. We take a zero- tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.

We will uphold all laws relevant to countering bribery and corruption in all the counties in which we operate. However, we remain bound by the laws in Ireland in respect of our conduct both at home and abroad.

This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as employees in this policy).

In this policy, third party means any individual or organisation you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.


1.5. Responsibilities
The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with other workers if they breach this policy.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future.

The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.  Management at all levels are responsible for ensuring those reporting to them are madeaware of and understand this policy and are given adequate and regular training on it.


1.6. Communication and Awareness
Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.

All employees are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.


Brian Whelan
Managing Director
July 2023