Bribery and corruption are, unfortunately, a feature of public and corporate life in many countries around the world. Governments, businesses and NGOs such as BOND, Transparency International and other organisations are working together to tackle the issue of bribery and corruption.
The company, while small and with a limited procurement or programme budget, does engage with suppliers and therefore needs a clear policy on anti-bribery and corruption to support our employees to make decisions in line with our values.
Our corporate conduct is based on our commitment to acting professionally, fairly and with integrity. The company does not tolerate any form of bribery and corruption.
Bribery is the offering, promising, giving, accepting or soliciting of money, gifts or other advantage as an inducement to do something that is illegal or a breach of trust in the course of carrying out an organisation's activities.
Corruption is the abuse of entrusted power for private gain.
The purpose of this policy is to set out the responsibilities of our employees in observing and upholding our values with respect to bribery and corruption.
This policy applies to all employees (permanent, temporary, volunteers) as well as contractors.
Bribery — We set out our commitment to operate responsibly and to ensure we engage with our stakeholders, to manage the ethical and social impact of our activities.
Our principle policy is a zero tolerance of bribery in any form, meaning that the company and its employees will not engage in bribery or any form of unethical payments including facilitation payments.
Conflicts of interest — All employees are required to avoid any activities that might lead to, or suggest, a conflict of interest with the business.
Gifts and hospitality — Employees must declare and keep a record of hospitality or gifts accepted or offered, which will be subject to managerial review.
Whistleblowing policy — Staff with information on bribery or corruption taking place within the organisation will be protected.
Payments under duress — In exceptional circumstances staff may feel bound to make a payment or payments in order to protect themselves against threats, including loss of liberty, life or limb.
Where these instances occur, staff will need to ensure they report back to management as soon as possible, giving a full account of the circumstances, amounts and any action taken to report the incident to the local authorities.
This policy is underpinned by the UK Bribery Act 2010.
We will communicate this policy and relevant guidance to employees, and we will also communicate this policy to our suppliers, contractors and business partners. Managers and employees will receive relevant training on how to implement this policy in the scope of their employment.
We will continue to review the implementation of this policy in respect of its suitability and effectiveness, and make improvements as appropriate.
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