Anti-Bribary & Corruption Policy

1. It is the Centre’s policy to conduct all of its business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, impartially, fairly and with integrity in all our business dealings and relationships with third parties wherever we operate, and implementing and enforcing effective systems to counter bribery and corruption. We will uphold all laws relevant to countering bribery and corruption but are bound by UK laws, including the Bribery Act 2010, in respect of our conduct in the UK and overseas.

 

2. This policy may be updated from time to time, to reflect newly identified risks and changes to law and best practice, and any amendments will be made available to the Centre’s staff and to third parties. This policy does not form part of any employee’s contract of employment.

 

3. The Centre’s Board of Directors has overall responsibility for ensuring this policy complies with the Centre’s legal and ethical obligations, and that the policy is complied with. This policy applies to all persons working for the Centre or on its behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners, sponsors, or any other person associated with us, wherever located.

 

4. The policy also affects all third parties coming into contact with the Centre. In this policy, by third parties we mean any individual or organisation the Centre comes into contact with during the course of its operations, 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.

 

5. In addition to instituting this policy, the Centre has taken steps to mitigate the risk of bribery and corruption, including: by ensuring that appropriate ethical information walls are in place in connection with any procurements being undertaken by policing and any investigations and enforcement action undertaken by policing; third parties wishing to associate with the Centre are required to complete a self-declaration, with the Centre undertaking a risk assessment where necessary; and, licensing arrangements and Branding Guidelines are in place in respect of any associations with the Centre. Any involvement by a third party coming into contact with the Centre in bribery and corruption may result in the Centre declining to engage with that party.

 

6. Any concern regarding compliance with this policy should be reported to the Centre Director in the first instance. The Centre is 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.

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7. It is a criminal offence to offer, promise, give, request, or accept a bribe. 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 could include money, gifts, loans, fees, hospitality, services, discounts, 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.

 

8. Individuals found guilty can be punished by up to ten years' imprisonment and/or a fine. As an employer, if the Centre fails to prevent bribery we can face an unlimited fine, exclusion from tendering for public contracts, and damage to our reputation. We therefore take our legal responsibilities very seriously and make our staff and those entities with which we work in any capacity aware of this policy.

 

9. We recognise that the Centre, in its role to develop partnership working between policing, the private sector and academia, and being staffed by serving police officers, is at risk of being subject to attempts to engage in bribery and corruption, for example in connection with:

1. procurements undertaken by policing;

2. investigations and enforcement action undertaken by policing; and/or,

3. the seeking of endorsements by the Centre or policing.

 

10. It is not acceptable for all persons working for the Centre or on its behalf in any capacity to:

1. 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;

2. give or accept a gift or hospitality during any commercial negotiations or tender process, if this could be perceived as intended or likely to influence the outcome;

3. accept a payment, gift or hospitality from a third party that is known or suspected to be offered with the expectation that it will provide a business advantage for the offeror or anyone else in return;

4. accept hospitality from a third party that is unduly lavish or extravagant under the circumstances;

5. offer or accept a gift to or from government officials or representatives, or politicians or political parties;

6. threaten or retaliate against another individual who has refused to commit a bribery offence or who has raised concerns under this policy; or,

7. engage in any other activity that might lead to a breach of this policy.

 

11. Nor is it acceptable for third parties coming into contact with the Centre in connection with Centre business to:

1. give, promise to give, or offer, a payment, gift or hospitality to any person working for the Centre or on its behalf with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;

2. give to any person working for the Centre or on its behalf or accept from an person working for the Centre of on its behalf a gift or hospitality during any commercial negotiations or tender process, if this could be perceived as intended or likely to influence the outcome;

3. accept a payment, gift or hospitality from any person working for the Centre or on its behalf that is known or suspected to be offered with the expectation that it will provide a business advantage for the offeror or anyone else in return;

4. accept hospitality from a from any person working for the Centre or on its behalf that is unduly lavish or extravagant under the circumstances;

5. threaten or retaliate against another individual working for the Centre or on its behalf who has refused to commit a bribery offence or who has raised concerns under this policy; or,

6. engage in any other activity that might lead to a breach of this policy.

7.  We do not make, and will not accept, facilitation payments or "kickbacks" of any kind.

 

12. Any failure to comply with this policy by persons working for the Centre or on its behalf in any capacity may constitute gross misconduct and result in disciplinary action in respect of employees, or in the termination of contractual arrangements in respect of others. Where appropriate, the matter may also be referred to the appropriate law enforcement agency and applicable regulatory bodies.

 

13. Any failure to comply with this policy by third parties coming into contact with the Centre in connection with Centre business may result in the termination of contractual arrangements, and where appropriate the matter may also be referred to the appropriate law enforcement agency and applicable regulatory bodies.

 

14. This policy does not prevent reasonable and appropriate hospitality or entertainment to be given to or received from third parties, where this is necessary for a legitimate business purpose, which means for the purpose of establishing or maintaining good business relationships, or marketing and presenting the Centre’s products and services effectively. Nor does it prevent the giving or acceptance of small gifts, having regard to the circumstances in which it is given, where these are given openly, and the gift is recorded.  Promotional gifts of low value, such as individual branded stationery, will usually be acceptable. As a rule, the value of any hospitality, entertainment or gift given to or received by an individual must not exceed £50. In addition, where it is proposed that hospitality, entertainment or gifts should be given to or received by a number of individuals from the same entity, their overall value should be taken into account and must not be excessive. 

 

15. Nor does the policy prevent the reimbursement of a third party’s expenses where these are reasonable and comply with the Centre’s policy.

 

16. Records of all hospitality, entertainment and gifts offered to or by those working for the Centre or on its behalf must be maintained, regardless of whether or not the hospitality, entertainment or gift was in fact accepted. These records may be subject to review and audit.

 

Last Reviewed: April 2021