Policies & procedures
Anti-Bribery Policy
This document covers all four family companies: ICD Energy Managers Ltd, PEP Energy, PEP-ICD Energy Managers Ltd and Cumbria Utilities Ltd.
We conduct our business honestly and ethically. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships, wherever we operate. This policy is written to comply with the Bribery Act 2010.
As an energy consultancy, our position between clients and suppliers depends entirely on trust. Nothing in the way we are remunerated, and nothing offered to or by us, may compromise the independence of the advice we give.
Who this policy covers
This policy applies to all directors, employees and anyone acting on behalf of any of the four companies in the PEP ICD family:
| Company | Registration | Location |
|---|---|---|
| ICD Energy Managers Ltd | Company no. 13138824 | Newcastle Upon Tyne |
| PEP Energy | — | Kendal, Cumbria |
| PEP-ICD Energy Managers Ltd | Company no. 14837509 | Newcastle Upon Tyne |
| Cumbria Utilities Ltd | Company no. 12341513 | Kendal, Cumbria |
What is bribery
A bribe is a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or anything else of value.
Under the Bribery Act 2010 it is an offence to offer, promise or give a bribe; to request, agree to receive or accept a bribe; to bribe a foreign public official; and, for a company, to fail to prevent bribery by persons associated with it. We do not, and will not, pay bribes or offer improper inducements to anyone for any purpose, and we do not accept them.
Independence of advice
Our recommendations to clients are based on analysis of their consumption, risk profile and the market — never on the commercial terms offered to us by a supplier. In particular:
- Supplier remuneration must never determine which suppliers are included in, or excluded from, a tender
- Commission arrangements are disclosed to clients in accordance with our terms and applicable regulation
- No employee may accept any payment, gift or benefit from a supplier in return for favourable treatment
Gifts and hospitality
Modest and proportionate gifts and hospitality, given or received openly in the normal course of business, are acceptable. They are not acceptable where they are secret, cash or cash-equivalent, disproportionate to the relationship, offered during a tender or negotiation in which the giver has an interest, or given with the intention — or the appearance — of influencing a decision.
All gifts and hospitality given or received above a nominal value must be recorded in the gifts and hospitality register maintained by the directors.
Facilitation payments
We do not make, and will not accept, facilitation payments or "kickbacks" of any kind. If an employee is asked to make such a payment, they must refuse and report the request immediately.
Third parties
We expect the same standards from those who act for us or with us — including introducers, sub-brokers, suppliers and professional advisers. Third-party arrangements must be documented, remuneration must be proportionate to legitimate services actually provided, and we reserve the right to terminate any relationship where we believe this policy has been breached.
Records
We keep financial records and maintain appropriate internal controls which evidence the business reason for making payments to third parties. Accounts must not be kept "off-book" to facilitate or conceal improper payments.
Raising a concern
Anyone — employee, client, supplier or member of the public — who suspects bribery or corruption in connection with our business should report it to the directors at enquiries@icdenergymanagers.com. Concerns are investigated promptly and treated in confidence. No one will suffer any detriment for raising a genuine concern, even if it turns out to be mistaken.
Responsibility and review
The directors of each company have overall responsibility for this policy, for its communication to all staff, and for reviewing its effectiveness. Breach of this policy is a disciplinary matter for employees and grounds for termination for third parties, and may be reported to the relevant authorities.
This policy is reviewed annually and was last reviewed in July 2026.