Counter Fraud, Bribery and Corruption Policy

Zero tolerance

Papillon does not tolerate fraud, bribery, corruption, theft, false accounting, invoice manipulation, collusion, conflicts concealed for gain or deliberate abuse of public or client funds. The policy applies to directors, workers, freelancers, agents, suppliers and anyone acting for or on behalf of Papillon.

Expected conduct

• Never offer, promise, give, request or accept a bribe, kickback, improper payment or advantage.
• Record transactions accurately and retain proportionate evidence for orders, delivery, supplier identity, bank-detail changes and payments.
• Declare actual, potential or perceived conflicts of interest before participating in a decision or assignment.
• Do not submit duplicate, inflated, false or misleading time, word-count, expense, invoice, tender or qualification information.
• Gifts and hospitality must be modest, legitimate, transparent and never linked to a procurement, referral or decision; anything that could appear improper must be declined and reported.

Prevention and detection

Papillon applies proportionate due diligence, identity and bank-detail verification, approval controls, reconciliation, access restrictions, audit trails and supplier monitoring. Higher-risk public-sector, overseas, intermediary or unusual payment activity receives enhanced scrutiny.

Reporting and response

Report concerns immediately to stevekent@papillontranslations.com with ‘Counter Fraud – Confidential’, or use the Whistleblowing Policy. Do not confront a suspect or alter evidence. Papillon will preserve evidence, restrict access where necessary, investigate or refer the matter, recover loss where appropriate and cooperate with clients, banks, police, regulators or counter-fraud bodies.

For suspected fraud affecting the NHS, concerns may also be reported to the NHS Counter Fraud Authority through its official reporting service. No person will be disadvantaged for raising an honest concern in the public interest.