Bribery is, in the conduct of the Organisation’s business, the offering or accepting of any gift, loan, payment, reward or advantage for personal gain as an encouragement to do something which is dishonest, illegal or a breach of trust. Bribery is a criminal offence. No gift should be given by any employee or third party working for or contracted by the organisation, nor hospitality offered, to any party in connection with the Organisation’s business without receiving prior written approval from the company's General Council.

The anti-bribery policy applies to third parties as well as Organisation employees. It applies to contractors, consultants, agency workers, partners and Organisation sponsors or any other third party associated with the Organisation.

Third parties working for the Organisation will not be allowed to accept, request or offer any reward, monetary or otherwise, to or from any person in return for providing or giving a favour.

Business gifts and hospitality

No business gift from any source can be accepted by any third party working on behalf of the Organisation without receiving prior written approval from the company's General Council.

Permission may be granted to accept a small gift, up to the value of £200. This will need to be recorded in the Organisation’s gift . Gifts over this amount should be declined.

No invitations to hospitality events from any source can be accepted by any third party working on behalf of the Organisation until they have been reported to the company’s General Council.

Permission may be granted for attendance and the third party is then permitted to respond to the invitation.

Offering gifts and hospitality

The Organisation may make small gifts to customers/clients, suppliers or others during the course of its business activities. These cannot be offered by third parties unless they have been authorised by the company’s General Council and an entry made in the gift register.

The Organisation will, from time to time, run hospitality events. These cannot be arranged by third parties working on behalf of the Organisation unless they have been authorised by the company’s General Council.

The General Council has overall responsibility for maintaining the record of gifts received and offered by the Organisation, as well as records of the hospitality received and offered by the Organisation.

The General Council is ultimately responsible for ensuring that all third parties working on behalf of the Organisation are aware of this policy. Day to day operation of this is delegated to those responsible for setting up the contractual arrangements and all third parties should be informed of the existence of this policy and its contents as part of their contractual arrangements with the Organisation.

Charitable donations

The person with overall responsibility for the Organisation’s charitable donations is the company's Group Financial Controller.

Third party donations to other charities made in the name of this Organisation are not permitted, without approval of General Council.

Donations will not be authorised where the charity is a political or lobbying cause, or where the donation is made for the purpose of achieving a business advantage.

Reporting concerns

Anybody concerned that bribery has or may occur in the Organisation, or that they may be being bribed, should inform their main point of contact in the first instance. If this is not appropriate, any department head, the General Council, HR or Managing Director should be informed.

Policy breaches