Created: 26 January 2016
Owner: HR
Version: 2.0
Last Amendment Date: January 2022
Next Review Date: July 2024
1. It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships, wherever we operate, and implementing and enforcing effective systems to counter bribery.
2. We will uphold all laws relevant to countering bribery and corruption and we remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct, both at home and abroad. The purpose of this policy is to:
3. Bribery and corruption are punishable for individuals by up to ten years' imprisonment. If we are found to have taken part in corruption, the Company could face an unlimited fine, be excluded from tendering for public contracts and face damage to our reputation. Therefore, we take our legal responsibilities very seriously, although we have not identified any particular risks for our business.
4. In this policy, third party means any individual or organisation you come into contact with during the course of your work for us. This 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.
5. This policy applies to all individuals working at all levels and grades. This includes senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as workers in this policy).
6. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
7. This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties. The giving or receipt of gifts is not prohibited, if the following requirements are met:
8. We appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered. However, as a public organisation our integrity, transparency and ethics should be of the highest standards possible.
9. It is not acceptable for you (or someone on your behalf) to:
10. We do not make contributions to political parties. We do not make charitable donations. No donation must be offered or made without the prior approval of the Chief Operating Officer.
11. You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All workers are required to avoid any activity that might lead to, or suggest, a breach of this policy.
12. You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future. For example, if a client or potential client offers you something to gain a business advantage with us or indicates to you that a gift or payment is required to secure their business.
13. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We also reserve our right to terminate our contractual relationship with other workers if they breach this policy.
14. We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.
15. You must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review.
16. You must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure.
17. All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept "off-book" to facilitate or conceal improper payments.
18. You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be raised with your line manager. Concerns should be reported by following the procedure set out in our Whistleblowing Policy.
19. Workers who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
20. We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Chief Operating Officer immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.
21. Training on this policy forms part of the induction process for all new workers. All existing workers will receive regular, relevant training on how to implement and adhere to this policy.
22. Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.
23. The Chief Executive has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
24. Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it.
25. ILF Scotland will monitor and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption. This policy does not form part of any employee's contract of employment and it may be amended at any time.
26. We shall retain records of data and information obtained in relation to this policy, for so long as necessary in accordance with applicable law and our Data Retention Schedule. It may also be necessary for us to share your information with third parties, such as fraud or crime prevention agencies, depending on any issues raised under this policy.
