Latitude Investment Management LLP 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:
Setting out a clear anti-bribery policy;
Training all consultants and clients, so that they can recognise and avoid the use of bribery by themselves and others;
Encouraging its consultants and clients to be vigilant and to report any suspicion of bribery, providing them with suitable channels of communication and ensuring sensitive information is treated appropriately;
Notifying all third parties that Latitude Investment Management LLP engages with of its policy and zero tolerance of bribery and/or corruption.
Rigorously investigating instances of alleged bribery and assisting the police and other appropriate authorities in any resultant prosecution;
Taking firm and vigorous action against any individual(s) involved in bribery.
Latitude Investment Management LLP prohibits the:
in order to
in order to
Latitude Investment Management LLP 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 Latitude Investment Management LLP 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 Latitude Investment Management LLP
The prevention, detection and reporting of bribery is the responsibility of all consultants throughout the Partnership. 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