The Foundation will not tolerate any sort of bribery or inducement, either to secure favours, or to bestow them, and which may be offered by (or to) its Trustees, staff, grantees, suppliers (including investment managers) or wider associates. This includes avoiding situations where there could be any reasonable suspicion of dishonesty, fraudulent behaviour or bribery committed or in any way condoned by those connected with the Foundation.
The Foundation, its Trustees or staff or other associated persons will neither make nor receive payments (or reimburse payments) of bribes (or ‘facilitation payments’) for any purposes. Foundation staff and associated persons are expressly prohibited from soliciting or offering benefits or rewards in return for services. Doing so will trigger disciplinary procedures, normally as gross misconduct, which are likely to result in dismissal. In some circumstances, it may also be a criminal offence under the Bribery Act 2010 for which the penalty may be a prison term or a fine or both.
Any person who suspects that bribery or fraud may have occurred should report these suspicions as soon as possible to the Director of Finance and Information Systems or to the Chair of the Audit & Risk Committee
In practice, the most likely form in which suspicions of bribery might arise at the Foundation are to do with offering or accepting gifts or hospitality. Our general approach is that, in addition to clear rules and norms about acceptable limits on hospitality, transparent declaration is a helpful guard against real or perceived impropriety. It also helps to maintain a culture where staff are aware of the need not only to be, but to be seen to be, alert to any imputations of conflict of interest or susceptibility to bribery or other unethical behaviour. Senior staff and Trustees are therefore required to complete a Gifts and Hospitality Register.