Forest of Dean Pink Elephant Project C.I.C.

Anti-Bribery and Corruption Policy

Contents

  1. Purpose and scope
  2. Principles
  3. Gifts and hospitality
  4. Facilitation payments
  5. Employee and associated person’s responsibilities
  6. Procedure
  7. Safeguard for employees
  8. Contacts

1 Purpose and scope

It is our policy to conduct all of our business in an ethical manner and do not tolerate any form of bribery and corruption. We are committed to acting professionally, fairly, with honesty and integrity in all our business activities and relationships.

This policy applies to all employees and associated persons (volunteers) of The Forest of Dean Pink Elephant Project C.I.C. (the Company), who perform duties and tasks in relation to, or on behalf of, the Company. This includes agency workers, consultants and contractors.

The purpose of this policy is to:

  • prevent bribery, in accordance with the Bribery Act 2010
  • set out the responsibilities of employees and associated persons
  • set out the consequences of any breaches to this policy.

2 Principles

  • All employees and associated persons are required to avoid any activity that might lead to, or suggest, a breach of this policy. Employees are encouraged to raise concerns of bribery or corruption affecting the Company.
  • This policy does not prohibit normal and appropriate gifts or hospitality.
  • The Company does not make or accept facilitation payments.
  • Victimisation of an employee who has raised a concern is a disciplinary offence.
  • If misconduct is discovered as a result of any investigation under this policy, the Disciplinary Procedure will be used.
  • Any concern made maliciously is a disciplinary offence.
  • Bribery Act 2010

Under the Bribery Act 2010, a bribe is a financial or other type of advantage that is offered or requested:

  • with the intention to encourage a person to perform their function or activity improperly
  • to reward a person for having already performed their function or activity improperly.

A criminal offence will be committed under the Bribery Act 2010 if:

  • an employee or associated person acting for, or on behalf of, the Company offers, promises, gives, request, receives or agrees to receive bribes
  • an employee or associated person acting for, or on behalf of, the Company offers, promises, or gives a bribe to a foreign official with the intention of influencing that official in the performance of their duties (where local law does not permit or require such influence)
  • the organisation does not have the defence that it has adequate procedures in place to prevent bribery by its employees and associated persons.

3 Gifts and hospitality

This policy does not prohibit normal and appropriate hospitality and gifts, given or received from third parties, as long as they are inexpensive in value and customary in nature. All gift or hospitality should be reasonable and justifiable, and the intention behind the gift should always be considered before accepting.

Payment for third party expenses is not prohibited but prior consent from your line manager is required for expenses which exceed £50.

All gifts received should be declared to your line manager and will normally go into a staff raffle. Any gifts deemed unusual or excessive should be refused. If unsure, check with your line manager or the Finance Director before accepting.

4 Facilitation payments

Facilitation payments are unofficial payments made to secure or expedite an action by a government official.

We do not make or accept facilitation payments. If you are asked to make a payment on the Company’s behalf, you should know what the payment is for and whether the amount requested is proportionate to the goods or service provided. A receipt detailing the reason for the payment should always be obtained. If you are unsure whether a payment is genuine, you should check with the Finance Director before making or agreeing to the payment.

5 Employee and associated person’s responsibilities

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 including volunteer staff. All employees and associated persons are required to avoid any activity that might lead to, or suggest, a breach of this policy.

It is not acceptable for an employee or someone on their behalf to:

  • give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given
  • give, promise to give, or offer, a payment, gift or hospitality to a government official, agent, or representative to ‘facilitate’ or expedite a routine procedure
  • accept payment from a third party that they know, or suspect is offered with the expectation that it will obtain a business advantage for them
  • accept a gift or hospitality from a third party that they know, or suspect is being offered or provided with an expectation that a business advantage will be provided in return
  • threaten or retaliate against someone who has refused to commit a bribery offence or who has raised concerns under this policy
  • engage in any activity that might lead to a breach of this policy.

Any employee who breaches this policy will face disciplinary action which could result in dismissal for gross misconduct. The Company reserves the right to terminate our contract with other workers if they breach this policy.

6 Procedure

Employees are encouraged to raise concerns at earliest possible opportunity. If unsure whether a particular act constitutes bribery or corruption, speak to your line manager or the Finance Director.

Any employee who has been offered a bribe; asked to make one; suspect that this may happen in the future; or believe that they are a victim of another form of unlawful activity should report this to your line manager or the Finance Director immediately. Should a situation arise where the employee is unable to approach a manager within the company, they can report their concern to their local police authorities.

The line manager or the Compliance Director will arrange for the concern to be investigated. They will investigate or request for a senior manager to conduct, depending on the nature of the concern. As part of the investigation, a meeting with the employee who raised the concern will be arranged in order to provide further information.

The investigator will report the concern, along with any actions or recommendations to the Senior Management Board.

The employee will be kept informed of the investigation’s progress and on conclusion will be informed of the outcome. Specific details of the investigation or outcome may not be given to the employee if sensitive or confidential. Any information regarding the investigation and outcome which is given should be kept confidential.

If the employee is not happy with the way in which their concern was handled or the outcome of the investigation, they should raise this with Chief Executive Officer.

7 Safeguard for employees

Raising a concern can be difficult, especially if worried about possible repercussions. Openness is encouraged and support will be given to those who raise concerns even if they turn out to be mistaken.

Employees must not suffer any detrimental treatment because of raising a concern. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If an employee believes that they have suffered any such treatment, they should inform HR immediately.

Employees must not threaten or retaliate against those who have raised concerns. Anyone involved in such conduct will be subject to disciplinary action.

If an employee raises a concern which is not confirmed during the investigation, no action will be taken against them for raising the concern in the first place.

8 Contacts

Lisa Harris / Stella Holt Tel: 07861 685080

Anti-Bribery & Corruption Policy v1.1 15/11/2024

Skip to content