What is prohibited
Do not offer, request, give or accept a payment, gift, favour or advantage intended to improperly influence a decision. This includes kickbacks for bookings, payments to secure shifts, false expenses and unofficial payments to speed up routine services. A bribe can involve something other than money and can be made through another person.
Gifts, hospitality and conflicts
Modest, legitimate business hospitality must have a clear business purpose and must not influence, or appear to influence, recruitment or purchasing decisions. Cash and cash-equivalent gifts are not acceptable. Anything beyond ordinary modest refreshments must be disclosed to a director and approved in writing before acceptance or expenditure. Where the director is involved, independent authorisation must be obtained.
Declare personal or financial interests in clients, suppliers or recruitment decisions. Step away from a decision where impartiality could reasonably be questioned. Donations or sponsorship must not be used to disguise a bribe.
Records and third parties
Keep accurate records of relevant gifts, approvals, expenses and payments. Do not create misleading invoices or use undisclosed accounts. Before appointing an intermediary, GRAFTD will establish their role, assess relevant risks and check that proposed fees and services are legitimate. We will communicate these standards to people acting for us.
Reporting and response
Refuse an improper request where it is safe, keep relevant evidence and report it promptly through our Raising Concerns Policy. If refusing would put someone in immediate danger, prioritise safety and report what happened when safe.
A director will assess the allegation fairly, seek independent advice where necessary and consider suspension of an affected transaction, contractual action or referral to the authorities. GRAFTD will support people who refuse a bribe or raise an honest concern.
The directors are responsible for implementing this policy, briefing the people who need it and reviewing concerns and corrective actions. We will review it at least annually and sooner if the law, our work or an incident requires it. This policy does not replace assignment terms or limit statutory rights.
Further guidance: Bribery Act guidance.