Anti-bribery and corruption policy

Why this policy exists

Re-engage is committed to carrying out its business fairly, honestly, and openly. We believe that we should not receive benefits of any kind from third parties which might reasonably be seen to compromise our personal judgement and integrity.

Re-engage values its reputation for ethical behaviour and financial probity and reliability and recognises that any involvement in bribery is both illegal and will adversely impact its image and reputation.

Charities risk losing support if there is a perception amongst the public (justified or not) that charity funds are being applied lavishly or wastefully. Similarly, trustees need to remember that accepting hospitality beyond the reasonable minimum, even if it costs the charity nothing, can give an impression of an inappropriate culture of extravagance, or inappropriate influence.

The aim of this policy is to help employees understand what to do if they are offered gifts and hospitality, and to provide a clear framework to ensure that all relevant parties understand what constitutes bribery, corruption, or exposes the charity to accusations (founded or unfounded) of unethical or unlawful behaviour.

Policy scope

This policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), no matter where they are located (within or outside of the UK). The policy also applies to volunteers, trustees, board, and / or committee members at any level.

In the context of this policy, third-party refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.

Where appropriate (for example when issuing a tender document for goods and services), the arrangements our company makes with a third party will be subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to anti-bribery and corruption.

This policy does not form part of an employee’s contract of employment and Re-engage may amend it at any time so to improve its effectiveness at combatting bribery and corruption.

The law

All staff, trustees and volunteers are required to comply with The Bribery Act 2010. The chief executive officer (CEO) is responsible for the policy in relation to this act.

The Bribery Act 2010 highlights two specific types of bribery that could lead to prosecution:

• The liability to prosecution if a person associated with Re-engage bribes another person..., where an associated person is one who performs services on or behalf of the organisation.
• Bribery of a foreign public official, where an official is one who holds a legislative, administrative, or judicial position in a territory or country outside the UK.

Definition of bribery

Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision.

A bribe refers to any inducement, reward, or object / item of value offered to another individual to gain commercial, contractual, regulatory, or personal advantage.

Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.

Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from their line manager immediately.

What is and what is not acceptable

This section of the policy refers to four areas:

• Gifts and hospitality
• Facilitation payments
• Political contributions
• Charitable contributions

Gifts and hospitality

Re-engage accepts normal and appropriate gestures of hospitality and goodwill (whether given to / received from third parties) so long as the giving or receiving of gifts meets the following requirements:

• It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits.
• It is not made with the suggestion that a return favour is expected.
• It is compliant with local laws.
• It is given in the name of the company, not in an individual’s name.
• It does not include cash or a cash equivalent (for example, a voucher or gift certificate).
• It is appropriate for the circumstances (for example, giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).
• It is of an appropriate type and value and given at an appropriate time, considering the reason for the gift.
• It is given / received openly, not secretly.
• It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.
• It is utilised by Re-engage for the purpose of raising funds in line with charitable objectives.
• It is not an offer to, or accepted from, a government official or representative or politician or political party, without the prior approval of the CEO and / or board of trustees.
• Invitations to attend formal fundraising events, local council dinners and awards ceremonies (this list is not exhaustive) should be accepted only after approval by a line manager or senior manager if the invitation is of a political nature.

Where it is inappropriate to decline the offer of a gift (that is, when refusal would cause unjustifiable offence), the gift may be accepted so long as it is declared to your line manager, who will assess and record the circumstances of the gift and donate it back to the charity for the purpose of raising funds.

Re-engage recognises that the practice of giving and receiving business gifts varies according to personal or business sector perceptions. In all circumstances, gifts given and received should always be disclosed to your line manager regardless of value (deemed or actual).

The intention behind a gift being given / received should always be considered. If there is any uncertainty, discuss this immediately with your line manager.

Facilitation payments and kickbacks

Re-engage does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action.

Re-engage does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage.

Political contributions

Re-engage will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage.

Employee responsibilities

As an employee of Re-engage, you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other anti-bribery and corruption information you are given.

All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy.

If you have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, you must notify your line manager.

If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct.

What happens if I need to raise a concern?

This section of the policy covers three areas:

• How to raise a concern
• What to do if you are a victim of bribery or corruption
• Protection

How to raise a concern

If you suspect that there is an instance of bribery or corrupt activities occurring in relation to Re-engage, you are encouraged to raise your concerns at as early a stage as possible. If you are uncertain about whether a certain action or behaviour can be considered bribery or corruption, you should speak to your line manager in the first instance.

Re-engage will familiarise all employees with its whistleblowing procedures so employees can vocalise their concerns swiftly and confidentially.

What to do if you are a victim of bribery or corruption

You must tell your line manager as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or may be asked to make a bribe or if you have reason to believe that you are a victim of another corrupt activity.

Protection

If you refuse to accept or offer a bribe or report a concern relating to potential act(s) of bribery or corruption, Re-engage understands that you may feel worried about potential repercussions. Re-engage will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken.

Re-engage will ensure that no one suffers any detrimental treatment because of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption.

Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment in relation to the concern the individual raised.

If you have reason to believe you have been subjected to unjust treatment because of a concern or refusal to accept a bribe, you should inform your line manager immediately.

Training and communication

Re-engage ’s anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third-parties at the outset of business relations, and as appropriate thereafter.

Re-engage will provide relevant anti-bribery and corruption training to employees etc. where we feel their knowledge of how to comply with the Bribery Act needs to be enhanced.

Record keeping

Re-engage will declare and keep a written record of the amount and reason for any hospitality or gifts accepted and given, and understand that gifts and acts of hospitality are subject to managerial review.