6.23 Anti-Bribery Policy

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1 6.23 Anti-Bribery Policy Message from the General Director At BMS World Mission we are committed to doing the right thing, the right way. This is more important than ever because of the strict new rules brought in by the Bribery Act 2010 (which commenced as law from 1 July 2011). In order to protect BMS and its officers from potential prosecution, the BMS anti-bribery policy is in part a response to the Bribery Act s requirement that agencies have adequate procedures to prevent involvement in corrupt practice. BMS are also committed to supporting the Anti-Bribery Principles and Guidance for Non-Governmental Organisations (NGOs) that was developed in 2011 by Mango and Transparency International UK for Bond, which is the UK umbrella network for NGOs. BMS operate a zero tolerance approach to the making or receiving of bribes or corrupt payments, in any form. This type of conduct is absolutely prohibited whether committed by employees or anyone else acting on the Charity s behalf. Bribery is not tolerated because it: diverts vital resources from the poor is a barrier to poverty alleviation and good governance breaches our Christian ethics and core values damages our reputation for sound financial management This policy sets out what is and is not acceptable, but if you are in any doubt as to whether any conduct could amount to bribery, the matter should be referred to the Director for Finance & Corporate Services, who is the Chief Compliance Officer for this policy. It is essential that you read and comply with this policy. David Kerrigan General Director Statement from the Chief Compliance Officer As Chief Compliance Officer for BMS in respect of bribery and corruption matters I have overall responsibility for our compliance in this area. The Finance & Audit Committee considers bribery and corruption risks as a standing item on its agenda. The Board is also updated on this topic on a regular basis and provided with ad hoc updates when necessary. Our lawyers advises the charity on the legal aspects of compliance. David Locke Director for Finance & Corporate Services BMS World Mission Page 1 of 7

2 Copies of the BMS Anti-Bribery policy are available from Finance & Corporate Services +44 (0) Contents 1 About this policy 3 2 Who must comply? 3 3 How do you comply? 3 4 Procedure for non-compliance 6 5 Speaking up reporting issues or bribery 6 6 If in doubt / advice 7 BMS World Mission Page 2 of 7

3 1 About this policy We recognise that practice varies across the territories in which BMS works and therefore what is normal and accepted in one place may not be accepted in another. However, we are fully committed to complying with our obligations under applicable legislation, including the Bribery Act 2010 (the Act ) which became law in July Please note that the Bribery Act 2010 acknowledges bribery or corruption as such: the offering, promising, giving, accepting or soliciting of money, a gift or other advantage as an inducement to do something which is illegal or a breach of trust in the course of carrying out an organisations activities The Bribery Act further notes that the purpose of a bribe is to; induce a person to perform improperly a relevant function or activity or to reward a person for the improper performance of such a function or activity. The Bribery Act further states that a bribe is paid or received; If a reasonable person in the UK would deem that it relates to the improper performance of a relevant function or activity. Please note that because BMS is a UK registered charity the actions of its personnel will make BMS subject to this legislation even if these definitions are not held in the jurisdiction where the offence occurs. If you are ever in doubt about a situation with which you are presented, always seek advice. You should contact the Director for Finance & Corporate Services on +44 (0) or in the first instance. 2 Who must comply? It is hoped that the BMS Anti-Bribery policy shall become mandatory for all BMS employees, agents, intermediaries, consultants, distributors, sub-contractors, suppliers and Joint Venture partners working on the Charity s behalf anywhere in the world ( Partners ), including the UK, following a programme of implementation. It is important that you take the time to read and comply with this Policy. The prevention, detection and reporting of any bribery in any form is the responsibility of all employees across BMS and all individuals and entities over which BMS has influence. Appropriate confidential channels for personnel, employees and partners are in place to report any suspicion of bribery; these are described later in this Policy. Any failure to comply with this Policy will be treated seriously and may result in disciplinary action. 3 How do you comply? As bribery appears in many forms, some of which you have less control over than others differing responses are required for different scenarios. In the event of: 3.1 Bribery BMS World Mission Page 3 of 7

4 BMS personnel and employees must: Refuse to pay a bribe or reject the offer of a bribe as defined by the Bribery Act 2010 Explain the BMS zero tolerance policy Make a note of where the bribe was solicited (and if possible the name of the corrupt individual) and report the incident to the BMS Compliance Officer and partner manager 3.2 Facilitation payments Whilst it is common practice to tip or facilitate public officials in many parts of the world, this practice is also covered under the Bribery Act s definition of corruption. Therefore when presented with a request for facilitation from a public official BMS personnel should do the following: Explain the BMS zero tolerance policy Report the request to local partners with a recommendation that they contact the public body involved to lobby for a proper allocation of resource Where payment is determined to be unavoidable and payment is made a receipt should be sought 3.3 Payments under duress BMS will work towards plans that reduce these zero sum scenarios that place life, limb or liberty at risk Never refuse to make a payment if faced with a threat of, or fear of, violence or loss of liberty. The safety of BMS personnel is a primary consideration. There is a defence of duress which is stated to be likely to be available in the case of payments made to protect life, limb or liberty Do not refuse to make a payment in humanitarian emergencies where there is risk of loss of life. If possible, please seek consultation with a senior member of BMS staff to decide if there is a genuine threat to life, limb or liberty Record the incident, including names, dates, details etc and send the record to the Compliance Officer Ask the host partner reporting the extortion to the relevant public authority 3.4 Gifts and hospitality When gifts are offered or where hospitality would appear to be disproportionately generous, it is sometimes the intention of the host to secure BMS commitment to the host s cause (be that a project, a mission placement, partnership etc). As rejection of hospitality and gifts can be of grave cultural offence, BMS personnel and employees must proceed in the following way: Make a record of the gifts received. The note should be sent to the Chief Compliance Officer who will maintain the gifts register and present it to the Audit Committee annually. The Director of Mission will then advise on how to proceed with critical decisions associated with the hosting group for a discretionary period of time In the event of receiving what amounts to more than a low value gift, the recipient should refuse the gift Any gifts offered must be acceptable within the policy of the receiver s charity/organisation and if you are in any doubts about acceptability no gift should be provided or accepted BMS World Mission Page 4 of 7

5 Hospitality or entertainment may only be accepted if: Employees or personnel from the partner or supplier are in attendance The supplier or partner does not pay any extravagant accommodation or (more than trivial) travel expenses for BMS employees The entertainment and/or acceptance of it could not be interpreted as a reward, inducement or encouragement for a favour or preferential treatment; and it is not unduly lavish or extravagant Reciprocal hospitality may be offered but needs to be approved by a Department Director, for example when partners visit the UK 3.5 Partners BMS will work towards informing all partner groups of their zero tolerance approach to bribery and corruption Before entering partnerships BMS managers and directors will ensure that they have conducted adequate due diligence. This should involve seeking information about partner s controls, including anti-bribery policies and procedures BMS will work towards gathering comprehensive list of partners own internal anti-bribery policies BMS will work towards all partnership agreements having appropriate anti-bribery commitments The Chief Compliance Officer along with the Director for Mission will advise on the level of due diligence required and the form of any anti-bribery clauses required in relation to an agreement. This is necessary due to the varying levels of exposure to corruption found in different locations 3.6 Suppliers, contractors, agents and other third parties BMS personnel will work towards communicating their zero tolerance policy to all contracted bodies such as immigration or customs agents, drivers, accountants, lawyers etc Before entering into contracting arrangements with local suppliers, agents or third parties, BMS personnel should assess the risk of bribery involved and conduct appropriate due diligence Contracts should be written wherever possible and should include an anti-bribery clauses 3.7 Conflicts of interest A conflict of interest arises in certain relationships, where individuals or the BMS donor constituency place their trust and confidence in someone to act in their best interests. A clash between professional obligations and personal interests arises if the individual tries to perform that duty while at the same time trying to achieve personal gain. For example, using BMS time or funds to engage in pre-existing personal projects overseas. The Compliance Officer will maintain a register of financial or personal interests that could present the possibility of conflicts of interest BMS personnel shall not participate in the decision-making process where there is a conflict of interest BMS World Mission Page 5 of 7

6 3.8 Political contributions BMS will not make grants or donations to political organisations or individuals, as a means of obtaining an advantage BMS respects the right of individual employees to make personal contributions, provided they are not made in any way to obtain an advantage From time to time, BMS may communicate views to government and others, on matters which affect its charity interests or those of its Trustees and employees, as a way of assisting in the development of regulation and legislation affecting the charity. 4 Procedure for non-compliance 4.1 For employees BMS starting position is that any act of bribery, in whatever form is unacceptable. We will consider taking disciplinary action against anyone who fails to comply with the anti-bribery policy up to and including dismissal. Failure to comply with this policy may also leave you open to a criminal prosecution under the Act. An offence under the Act can result in a fine and/or up to a maximum of ten years imprisonment. 4.2 For BMS A breach of this Policy by an employee or partner could result in BMS breaching the Bribery Act. An offence under the Act can result in BMS being fined and would likely lead to negative publicity and serious damage to the reputation of the BMS brand. 5 Speaking up reporting bribery BMS aims to conduct mission with the highest standards of ethics, honesty and integrity, and recognises that you have an important role to play in maintaining this aim. Any employee concerned about any form of malpractice, improper action, or wrongdoing by the Charity, its employees or other stakeholders are strongly encouraged to report the matter to their Regional Team Leader (RTL), Director or the Chief Compliance Officer. BMS believes it is essential to create an environment in which personnel feel able to raise any matters of genuine concern internally without fear of disciplinary action being taken against them, that personnel will be taken seriously and that the matters will be investigated appropriately and as far as practicable be kept confidential. BMS believes that any employee with knowledge of bribery in any form should not remain silent. BMS takes all matters of malpractice, improper action or wrongdoing very seriously and you are strongly encouraged to raise incidents or behaviour that are not in accordance with the policy, by following the procedure set out below: Line manager In the first instance, you should consider raising your concerns with your line manager (for overseas mission personnel this will mean the RTL). He/she has a responsibility to listen and respond to any matter that is of concern to you. Concerns can be raised verbally or in writing. Your line manager will determine whether he/she is able to investigate the concern directly, keeping the Director for Finance & Corporate Services updated, if appropriate, of progress and its conclusion. BMS World Mission Page 6 of 7

7 If your line manager is unable to resolve the issue locally, he/she will refer the concern to the relevant department director and the Director for Finance & Corporate Services, who will manage your concern in accordance with the Independent Internal Individual process set out below. Senior manager If you feel that you cannot raise your concern with your line manager, for whatever reason, you should contact the director of your department, who will consider the matter, manage any investigation, keeping the Director for Finance & Corporate Services informed, if appropriate, of progress and its conclusion. If the department Director is unable to resolve the issue locally, he/she will transfer the concern to the Director for Finance & Corporate Services, who will manage your concern in accordance with the independent internal individual process set out below. Independent internal individual If you feel you need to raise the issue outside of your immediate working environment, you should contact the Corporate Services Manager on +44 (0) or The Corporate Services Manager will record the concern and determine the appropriate approach to take in managing any investigation, including whether to appoint an external independent individual to review the matter, or refer it to the appropriate internal or external body. The Director for Finance & Corporate Services will inform the General Director, the Director for Mission and the Finance & Audit Committee Chairman of any serious issues as a matter of urgency. BMS recognises that there may be some cases where no wrong doing is found through internal procedures. Protection will be given and no disciplinary action taken if the disclosure is reasonable, made in good faith and the information believed to be true. Audit Committee review The Audit Committee reviews arrangements by which employees may, in confidence, raise concerns about possible inappropriate activity. The Committee reviews concerns raised make sure that any significant matters receive independent investigation and appropriate follow up action. Secondment agreements Host partnership organisations may have their own policies on anti-bribery. These should be followed to the letter except where the advice contradicts or falls short of the requirements noted in this policy. 6 If in doubt / advice If you have any questions you should contract the Director for Finance & Corporate Services on +44 (0) or Please ensure that you keep up to date with communications and updates on the intranet. Michael J Quantick Corporate Services Manager 28 November 2012 BMS World Mission Page 7 of 7

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