POLICY STATEMENT
Academic Action takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships wherever it operates and to implementing and enforcing effective systems to counter bribery and corruption. This policy applies to all Academic Action’s employees, volunteers and those contractors working for Academic Action (for example casual workers, agency staff and staff on secondment from other organisations). References to ‘staff’ or ‘you’ in this policy therefore covers trustees, employees, volunteers and contractors. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy. Training on this policy will form part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and delivery partners at the outset of our business relationship with them and as appropriate thereafter. Delivery partners and sub-contractors should have their own policy but checks should be made that this meets the standards of this policy. In the event that it does not this policy may be shared with them.
About this policy
The purpose of this policy is to:
(a) set out our responsibilities, and of those working for us, in observing and upholding our position on bribery and corruption;
(b) provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues;
(c) set out the limited circumstances in which gifts and hospitality can be accepted and/or given.
Under the Bribery Act 2010 it is a criminal offence to offer, promise, give, request, or accept a bribe. Individuals found guilty can be punished by up to ten years’ imprisonment and/or a fine. As an employer if we fail to prevent bribery we can face an unlimited fine, exclusion from tendering for public contracts, and damage to our reputation. Bribery and corruption and also have a detrimental impact on our beneficiaries and how we best serve them. We therefore take our legal responsibilities very seriously.
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. This may include people connected to you, such as friends or family members.
This policy does not form part of any employee’s contract of employment and we may amend it at any time.
Links to other policies
Other internal policies which may be relevant to this policy are:
- Whistleblowing Policy – if you have a genuine concern about any potential wrongdoing (particularly if it does not fall within the scope of another policy) you should report it under the whistleblowing procedures.
- Fraud and Theft Policy – an act of bribery might also fall within the definition of fraud.
- Anti-Money Laundering Policy – Academic Action has a responsibility to report on all money laundering suspicions and any concerns or suspicions regarding financial or non-financial support for terrorist activities. Such concerns must be acted on immediately.
- Conflicts of Interest Policy – Trustees
- Staff Code of Conduct
Definitions and examples of bribery and corruption
Bribery is offering, promising, giving or accepting any financial or other advantage, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage.
An advantage includes money, gifts, loans, fees, hospitality, services, discounts, information on or the award of a contract or anything else of value.
A person acts improperly where they act illegally, unethically, or contrary to an expectation of good faith or impartiality, or where they abuse a position of trust. The improper acts may be in relation to any business or professional activities, public functions, acts in the course of employment, or other activities by or on behalf of any organisation of any kind.
Corruption is the abuse of entrusted power or position for private gain.
Any form of bribery or corruption is strictly prohibited by Academic Action. Further, we do not make, and will not accept, facilitation payments or “kickbacks” of any kind.
Facilitation payments, also known as “backhanders”, or “grease payments” are typically small, unofficial payments made to secure or to expedite a routine or necessary action (for example by a government official). They are not common in the UK.
Kickbacks are typically payments made in return for a business favour or advantage. Examples would include the following:
- Offering a potential business partner tickets to a high profile event, but only if they agree to (or there is an expectation that they will agree to) enter into a contract with us;
- A supplier gives a job to your family member, but makes it clear that they expect you to do what you can to ensure that we continue to do business with them;
These examples are not exhaustive.
For more information reed the the full document here: