IGD values its reputation for conducting our business in an honest and ethical manner. Any involvement in bribery would reflect adversely on our image and reputation and 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.
We will uphold all laws relevant to countering bribery and corruption. However, we remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct both at home and abroad.
Bribery and corruption are punishable for individuals by up to 10 years’ imprisonment and if IGD is found to have taken part in corruption, IGD could face an unlimited fine and be excluded from tendering for public contracts. We therefore take our legal responsibilities very seriously.
For employees, any breach of this policy will be regarded as misconduct, leading to disciplinary action up to and including summary dismissal. For further details please refer to the disciplinary policy in the employee handbook. This policy does not form part of the terms and conditions of employment and can be amended at any time.
Who is covered by the policy?
This policy applies to all individuals who work for IGD including senior managers, officers, directors, employees (both permanent and fixed term), consultants, contractors, agency staff, interns and any other persons who will perform services for IGD or on our behalf (collectively referred to as employees and associated persons in this policy).
What is bribery?
A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
IGD prohibits employees and associated persons from offering, promising, giving, soliciting or accepting any bribe. The bribe might be cash, a gift or other inducement to, or from, any person or company whether a public or government official, political party or a private person or company regardless of whether the worker is situated in the UK or overseas. The bribe might be made to ensure that a person or company improperly performs duties or functions (for example by not acting impartially or in good faith or in accordance with their position of trust) to gain any commercial, contractual or regulatory advantage for the organisation in either obtaining or maintaining business, or gain any personal advantage, financial or otherwise, for the individual or anyone connected with the individual.
Records
It is essential that all employees and associated persons take particular care to ensure that all company records are accurately maintained in relation to any contract or business activities including financial invoices and all payment transactions with clients, suppliers and public officials.
All hospitality, gifts or expenses incurred to third parties must be submitted in accordance with IGD’s expense procedure and specifically record the reason for the expenditure.
Our definition of a third party is any individual or organisation an employee or associated person comes into contact with during the course of his/her work. This will include actual and potential customers, suppliers, business contacts, agents, advisors government and public bodies including their advisors, representative and officials.
All hospitality and gifts received and given must be recorded in the gift book together with the reason for the gift/hospitality.
Due diligence should be undertaken by all employees and associated persons prior to entering into any contract, arrangement or relationship with potential suppliers of services, agent, consultant or representative.
Gifts and hospitality
IGD permits corporate entertainment, gifts and hospitality that it is undertaken:
- for the purpose of establishing or maintaining good business relationships
- to improve the image or reputation of IGD; or
- to present IGD’s goods and services effectively.
Provided that it is arranged in good faith, and it is not offered, promised or accepted to secure an advantage for IGD or any of its employees and associated persons or to influence the impartiality of the recipient.
IGD will authorise only reasonable, appropriate and proportionate entertainment.
Employees, and where appropriate associated persons, should inform the line manager of all proposed hospitality well in advance. The proposal should:
- highlight the objective of the entertainment
- identify who will be attending
- the organisation they represent and
- the rational for the proposal.
IGD will only approve business entertainment where there is a clear business objective and there is no conflict of interest. If the line manager requires further clarification as to the suitability of the proposed hospitality they should speak with IGD’s Legal Counsel.
Any gifts, rewards or entertainment received or offered from customers, public officials, suppliers or other business contacts should be recorded in the gift book irrespective of value.
In certain circumstances it may not be appropriate to retain such gifts or to be provided with the entertainment and IGD’s Legal Counsel may ask for the gift to be returned to the sender or to refuse the entertainment, for example, where there could be a real or perceived conflict of interest. As a general rule, small tokens of appreciation, such as flowers or a bottle of wine, may be retained or shared with colleagues.
Whilst it is appreciated that the giving and receiving of gifts varies between countries and regions the test to be applied is whether in all circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.
Facilitation payments
IGD prohibits its employees or associated persons from making or accepting any facilitation payments. These are payments made to government officials for carrying out or speeding up routine procedures. Facilitation payments or offers of such payments will constitute a criminal offence by both the individual concerned and IGD under the Bribery Act 2010, even where such payments are made or requested overseas. Employees and associated persons are required to act with greater vigilance when dealing with government procedures overseas.
Where a public official has requested a payment, employees or associated persons should ask for further details of the purpose and nature of the payment in writing. This should be reported to IGD’s Legal Counsel who will consider the nature of the payment. If it is concluded that the payment is a legitimate fee, for example part of a genuine fast track process, or is permitted locally, IGD will authorise the employee to make the payment.
Where the Director of Legal considers that the request is for a facilitation payment, the employee or associated person will be instructed to refuse to make the payment and notify the public official that the matter will be reported to the Company and UK embassy.
IGD recognises that in some countries, an employee’s own welfare and safety could be at risk if they do not make a facilitation payment. In this case the payment should be made and reported promptly to the Director of Legal. IGD will not take disciplinary action against an employee who makes such a payment in the belief that they will be at risk if they do not do so.
How to raise a concern?
IGD depends on its employees and associated persons to ensure that the highest standards of ethical conduct are maintained in all its business dealings. Employees and associated persons are requested to assist IGD and to remain vigilant in preventing, detecting and reporting bribery.
IGD encourages employees and associated persons to raise concerns about any issue or suspicion of malpractice at the earliest opportunity. Where you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be raised with the Director of Legal. Concerns should be reported by following the procedure set out in our whistle blowing policy, a copy of which can be found in the employee handbook.
Any report of bribery will be thoroughly and promptly investigated in the strictest confidence. Employees and associated persons will be required to assist in any investigation into possible or suspected bribery.
Employees or associated persons who raise concerns or report incidents of bribery will not suffer any detrimental treatment as a result of refusing to take part in bribery or corruption or because of reporting their suspicions in good faith. Any instance of detrimental treatment by a fellow employee as a result of a report of bribery being made, will be treated as a disciplinary offence.
Employees suspected of bribery may be suspended from their duties while the investigation is being carried out. IGD will invoke the disciplinary procedures where the employee is suspected of bribery and proven allegations may result in a finding of gross misconduct and immediate dismissal. IGD may terminate the contracts of any associated persons, including consultants and other workers who act for, or on behalf of, IGD who are found to have breached this policy.
IGD may also report any matter to the relevant authority, including the Director of Public Prosecutions, Serious Fraud Office, Revenue and Customs Prosecutions Office and the police. IGD will provide all necessary assistance to the relevant authorities in any subsequent prosecution.
Training and communication
Training on this policy forms part of the induction process for all new employees. All employees will receive regular, relevant training on how to implement and adhere to this policy.
Responsibilities
The Trustees and Internal Board have overall responsibility for ensuring this policy complies with our legal and ethical obligations and that all those under our control comply with it. Because financial management falls under the remit of the Audit Committee, the Audit committee are responsible for reviewing this policy prior to it being ratified by the Board.
IGD’s Legal Counsel has primary and day to day responsibility or implementing this policy and for monitoring its use and effectiveness.
IGD’s Legal Counsel should review this policy from a legal and operational perspective at least once a year. In addition IGD’s Legal Counsel will review the gift log biannually.
All employees and associated persons are responsible for the success of this policy and should ensure they use it to disclose any suspected danger of wrongdoing.
Review and Monitoring
Because internal controls and risk management falls under the remit of the Audit Committee, the Audit committee are responsible for reviewing this policy prior to it being ratified by the Board.
This policy was last reviewed and approved by the Board of Trustees on 22 November 2022.