1. Introduction

Transparency International UK (TI-UK)’s Anti-Bribery Programme, which is set out on this page, is compatible with the Business Principles for Countering Bribery and the Bond AntiBribery Principles for NGOs (Bond Anti-Bribery Principles). The full document, including Annexes, can be downloaded here.

2. Principles

The TI-UK Programme is based on the seven Bond Anti-Bribery Principles: 

High-level commitment

The Board of Trustees and senior management are committed to and oversee the implementation of a policy of zero-tolerance, recognising that bribery is contrary to fundamental values of integrity, transparency and accountability and undermines organisational effectiveness.

Risk assessment

Bribery risk assessment is an integral part of the organisation’s overall and ongoing risk management process.

Devise and implement robust anti-bribery procedures

TI-UK has devised and is implementing and maintaining robust procedures (set out in this document) which are proportionate to the risks and to the size, resources and complexity of the organisation. 

Due-diligence assessment of partners, agents and contractors

TI-UK assesses the bribery risk associated with entering into partnership or contracting arrangements with other entities and then carries out periodic due diligence based on that risk assessment. Partnership or contractual arrangements are checked to ensure that these organisations have policies and procedures which are consistent with TI-UK’s own procedures.

Dissemination and communication

TI-UK has established means for effective internal and external communication of its policy and procedures. The organisation undertakes training and awareness programmes to ensure staff, agents and partners are aware of the potential risks, how bribery might affect them, what they should do if they are offered a bribe, and the consequences should they be found to have made or received a bribe. 

Monitoring and evaluation

Implementation of anti-bribery procedures is monitored as part of overall risk management and internal control processes. Periodic reviews of anti-bribery procedures are made and reported as part of governance and accountability processes.

Collective action

TI-UK is committed to sharing information and strengthening collective action to prevent bribery.

In addition, TI-UK adheres to two other important principles:

  • Openness. TI-UK strongly encourages a culture of openness in which bribery risks are discussed, in order to respond better both to immediate circumstances and in the longerterm.
  • Transparency. TI-UK commits to be fully transparent about both its approach to antibribery and all relevant information such as entries to the gifts and hospitality registers and sources of its funding.

3. TI-UK’s Policy

TI-UK has a zero tolerance policy towards the giving and receipt of bribes, and of bribery and corruption in any form. TI-UK aspires to operate to best practice standards, and complies with all relevant laws in all the jurisdictions in which it operates. This policy extends to all of TI-UK’s dealings and transactions in all countries in which it or its consultants and associates operate. This policy underpins TI-UK’s anti-bribery programme, which is regularly revised to capture changes in corruption risk, law and best practice. All Trustees, members of the Advisory Council, employees, consultants and volunteers are required to comply with this policy.

This policy has been approved by the TI-UK Board and is incorporated in all TI-UK contracts of employment and consultant or partner contracts. 

4. TI-UK’s anti-bribery Programme

4.1 Risk assessment

TI-UK undertakes periodic assessments of the bribery risks that it faces. The key areas of risk identified are:

  • Gifts
  • Hospitality
  • Overseas travel
  • Receipt of donations
  • Conflicts of interest
  • Research activities
  • Appointment and activities of consultants.

 

4.2 Robust anti-bribery procedures

TI-UK’s procedures are primarily designed to mitigate the risks identified by the risk assessment. The procedure for each of these is identified below.

4.2.1 Gifts

TI-UK’s policy on the giving and receiving of gifts is:

  • No TI-UK Trustee, Advisory Council (AC) member, employee, consultant or volunteer accepts directly or indirectly any discount, gift, entertainment (which includes meals, cultural events, tourist visits etc) or favours (referred to as gifts) that may influence or be perceived to influence the exercise of their official function, or the performance of their official duties or their judgement. Examples of criteria for making such judgements are attached in Annex 1.
  • All gifts with a value of more than £75 are refused. All gifts between the value of £30 and £75 are registered in the TI-UK register of gifts. Such gifts are reported to the Chief Executive (CE) and via them to the Board. The register is maintained by a staff member delegated by the CE. The register is available for the information of all TI-UK trustees, AC members, employees, consultants and volunteers. It is also publicly available on the TI-UK website.
  • Gifts with a value below £30 should be reported to the recipient’s line manager and may be kept by staff unless there are particular reasons to refuse the gift or add it to the register.

Each individual, and ultimately their line/project manager (as appropriate), is responsible for ensuring that the gifts register is completed.

4.2.2 Hospitality

Hospitality includes meals, entertainment, transport, accommodation and any other activities that could reasonably be interpreted as offering or receiving hospitality. TI-UK’s policy on giving and receiving hospitality is:

  • No TI-UK trustee, AC member, employee, consultant or volunteer:
  • Accepts directly or indirectly any hospitality (as defined) that may influence or be perceived to influence the exercise of their official function, or the performance of their official duties or their judgement. Examples of criteria for making such judgements are attached in Annex 1.
  • Offers directly or indirectly any hospitality (as defined) that may influence or be perceived to influence improperly the actions of other persons (including foreign public officials). Examples of criteria for making such judgements are attached in Annex 1.

All hospitality received or given of a value estimated to exceed £50 is reported to the Chief Executive and recorded in a register that is maintained by a staff member delegated by the CE. The register is available for the information of all TI-UK trustees, AC members, employees, consultants and volunteers. It is also publicly available on the TI-UK website.

Each individual, and ultimately their line manager/project manager (as appropriate), is responsible for ensuring that the hospitality register is completed.

4.2.3 Overseas Travel

Overseas travel is a key risk area for TI-UK, and its zero tolerance policy applies equally to overseas travel.

In particular, TI-UK recognises that facilitation payments are bribes and illegal. Facilitation payments are small payments made to secure or speed up routine actions, usually by public officials, such as issuing permits, immigration controls, providing services or releasing goods held in customs. Induction training for new employees on anti-bribery and corruption includes specific guidance as to how to avoid circumstances where facilitation payments can arise. It is also our policy that we require that our agents and other intermediaries, contractors and suppliers do not make facilitation payments and other bribes on our behalf.

When there is a suspicion that a payment might be considered a facilitation payment, it should only be made if the official or third party can provide a formal receipt or written confirmation of its legality. If practicable, senior management approval should be obtained for the payment.

If a payment demand is accompanied by immediate threat of physical harm, then the over-riding principle is to put safety first. In these circumstances, the payment should be made and then reported immediately to the Chief Executive, recording the circumstances and amount of the payment. TI-UK will also report any such incidents to the relevant UK and foreign authorities.

4.2.4 Receipt of Donations

TI-UK recognises that donations represent a corruption risk, in particular in cases where a donor may seek to compromise TI-UK’s independence by influencing improperly the policies, activities or decision-making of TI-UK. TI has a global policy (applicable to the Secretariat and all national chapters) on the receipt of donations, which has been supplemented by a TI-UK policy on anonymous donations. These are reproduced in Annex 2.

 

4.3 Conflicts of Interest

TI-UK recognises that conflicts of interest may arise that could lead to Trustees, AC members, employees or consultants taking decisions, or appearing to take decisions, that are based on personal interest and not the interest of the organisation. Such conflicts of interest can be a form of corruption. TI-UK therefore has a policy on conflicts of interest, which is attached in Annex 3.

4.3.1 Independence of Research

TI-UK publishes research on a regular basis. The Board and CE are required to take all necessary precautions to ensure that the integrity of decision-making in the subjects selected for research, the research process, the presentation of the results and the means of publication are not compromised by external interests.

4.3.2 Consultancy Services

TI-UK recognises that consultancy and advisory services are high-risk due to the contractual association of TI-UK with clients that are perceived to have engaged in corrupt behaviour and the potential for clients to approach TI-UK with the intention of improperly enhancing their own TI-UK reputations. TI-UK has therefore put into place procedures to mitigate these risks. These are attached as Annex 4.

4.3.3 Appointment and Activities of Consultants

Certain areas of TI-UK activities make extensive use of external consultants. It is TI-UK policy that they should be properly vetted to ensure that they have not previously been associated with corrupt activity; their contractual arrangements require adherence to TI-UK’s anti-bribery policy and procedures and they receive appropriate training; and that TI-UK’s contracts with them allow for termination of a relationship in the case of a breach of TI-UK’s anti-bribery policy.

 

4.4. Use of Partners and Agents

Certain areas of TI-UK’s work may require the use of partners and agents. It is TI-UK policy that they should be properly vetted to ensure that they have not previously been involved in corrupt activity; their contractual arrangements require adherence to TI-UK’s anti-bribery policy and procedures and they receive appropriate training as appropriate; and that TI-UK’s contracts with them allow for termination of a relationship in the case of a breach of TI-UK’s anti-bribery policy.

 

4.5 Dissemination and Communication

4.5.1 Induction

All employees, consultants, board members, AC members and volunteers are inducted into this policy. The policy forms part of the contract or agreement for each of these parties.

4.5.2 Training

All employees, consultants and volunteers receive basic training in how to understand and avoid bribery. Those giving the training are also seen as having received the training. The effectiveness of the training is evaluated and reported on a quarterly basis to the Senior Leadership Team. This ensures that new recruits are undertaking the training but also that it continues to meet their expectations and training needs. Those in high-risk positions receive more detailed training based on the risks they will be facing.

High-risk positions are currently categorised as:

  • Those involving travel to countries that are high-risk for bribery
  • Those in which individuals are responsible for procurement of goods and services
  • Those in which individuals are responsible for recruitment
  • Those in which individuals are responsible for fundraising
  • Those in which individuals are responsible for commissioning or over-seeing research
  • Those in which individuals are exposed to any of the other high-risk areas highlighted in 4.1

4.5.3 Communication to all Partners and Stakeholders

TI-UK’s policy and procedures are made publicly-available and are published on the TI-UK website.

 

4.6 Monitoring and Evaluation

TI-UK’s anti-bribery programme is reviewed periodically by the Chief Executive and the SLT. This will typically cover:

  • a review of the risk assessment
  • a review of training and training records
  • a review of the gifts register
  • a review of the hospitality register

 

4.7 Collective Action

Since TI-UK is an anti-corruption organisation operating largely in the UK, there are limited opportunities for TI-UK to participate in collective action in order to eliminate any bribe-paying. However, TI-UK strongly supports the principle of collective action, and offers advice and expertise to others genuinely seeking to pursue collective action.

 

4.8 Confidential Reporting

TI-UK’s confidential reporting procedures are designed to reflect the size of the organisation. Allegations can be sent via the Reportingconcerns@transparency.or.uk email where they will be logged and actioned by a senior employee (normally the COO). A key principle of TI-UK’s anti-bribery programme is openness, and all employees and other parties are encouraged not simply to report concerns and incidents, but to generate active discussion about them in order to respond better both to immediate circumstances and in the longer-term.

TI-UK has a separate policy on Whistle-blowing for breaches of procedure that are in the public interest. This details the procedures to be followed and the bodies to which reports may be made. It contains, inter alia, provisions on confidentiality and protection for bona fide whistle-blowers.

 

4.9 Responses

TI-UK will investigate any credible allegations of bribery and / or corruption using internal or, if necessary, external resources to do so. Commissioning that investigation will be the responsibility of the Chief Operating Officer or, if they are in any way implicated in the allegations, of the Chief Executive.

Investigations will be concluded as rapidly as is possible without compromising their integrity or thoroughness.

In the event that reporting to the Chief Executive and / or Chief Operating Officer is either not effective or inappropriate, whistle-blowing can be channelled through the Chair of the Board who may choose to refer it to the Ethics Advisory Panel. Alternatively, employees may contact the Ethics Advisory Panel Chair in confidence (Ethics@transparency.org.uk).

Should the allegations be proven, TI-UK may take any or all of the following actions:

• disciplinary action up to and including gross misconduct leading directly to dismissal;

• reporting the incident to the police or other authorities in relevant countries;

• legal action to recover lost assets.

All investigations, whatever their outcome, will be logged and reported to the Board. Where required, reports will also be made to the Charity Commission through Serious Incident Reporting. Requirements to report to donors will be followed in a timely manner and in line with funding agreements.

TI-UK encourages all employees to report details immediately if they suspect that bribery and / or corruption has been committed or see any suspicious acts or events. Malicious accusations may be the subject of disciplinary action.

 

5.0 Application of this Programme

This Programme is applicable to:

  • All TI-UK employees
  • Any consultant contracted by TI-UK while acting on TI-UK business, whether in a paid or unpaid capacity
  • Any board member, AC member or adviser while acting on TI-UK business, whether in a paid or unpaid capacity
  • Any volunteer or intern while acting on TI-UK business.

Each individual is personally responsible for ensuring that they adhere to the policy and procedures in this Programme. Line/project managers share this responsibility through monitoring the activities and performance of those they are managing.

 

5.1 Review

This policy is reviewed by the Senior Leadership Team every two years and approved by the Board. Where recommendations from external audit, the Charity Commission or other UK legislation demands or as a result of learning from incidents this policy may be up-dated more frequently.

 

 

Annex 1: Example criteria to test if gifts, hospitality or reimbursed expenses comply with the anti-bribery programme:

Gifts, hospitality or reimbursed expenses should meet the following criteria:

  • Made for the right reason: if a gift or hospitality, it should be given clearly as an act of appreciation, if travel expenses then for a bona fide business purpose
  • No obligation: the gift, hospitality or reimbursement of expense does not place the recipient under any obligation
  • No expectations: expectations are not created in the giver or an associate of the giver or have a higher importance attached to it by the giver than the recipient would place on such a transaction
  • Made openly: if made secretly and undocumented then the purpose will be open to question;
  • Accords with stakeholder perception: the transaction would not be viewed unfavourably by stakeholders if it were made known to them
  • Reasonable value: the size of the gift is small and the value of the hospitality or reimbursed expense accords with general business practice in the charitable sector
  • Appropriate: the nature of the gift, hospitality or reimbursed expense is appropriate to the relationship and accords with general business practice in the charitable sector
  • Legality: it is compliant with relevant laws
  • Conforms to the recipient’s rules: the gift, hospitality or reimbursement of expenses meets the rules or code of conduct of the recipient’s organisation
  • Infrequent: the giving or receiving of gifts and hospitality is not a regular happening between the giver and the recipient
  • Reported: the gift, hospitality or expense should be recorded and reported to management
  • Documented: the expense is fully documented including purpose and approvals given and properly recorded in the books

 

Annex 2: Policies of TI-Secretariat and TI-UK on Receipt of Donations

TI-S policy – to which TI-UK subscribes – is as follows:

Introduction

Donations and other income enable TI to fight corruption. TI needs to secure the funding necessary to undertake its vital work. Secure and diverse funding enables TI to maintain its independence, protect its reputation and operate effectively. We will not accept funds that might harm the reputation of the organisation or impair its independence to pursue its mission.

Background

The National Chapters and the Secretariat of TI (TI-S) are funded from diverse sources: foundations, governments, the private sector, individuals, membership fees, income from publications, events and other activities and from an endowment fund. Relying on many sources of income helps TI to maintain its independence. Funding may be unrestricted or tied to specific projects.

Generally, the National Chapters and TI-S ('TI Bodies') each raise their own funding. As regards fundraising for the Secretariat, the Donor Relations department leads and coordinates fundraising activities at TI-S. A sub-committee of the TI Board, the Fundraising Task Force, pursues and oversees major fundraising initiatives for the movement. This committee also advises on all matters referred to it under the procedure described below. TI must not risk jeopardising its reputation for honesty, openness and integrity. Its reputation could be compromised if a TI body received funding from sources that were perceived to be pursuing activities inconsistent with TI's mission.

Policy

It is TI's policy to accept funding from any donor and whether monetary or in kind, provided that acceptance does not:

  • impair TI's independence to pursue its mission
  • endanger its integrity and reputation

Scope

This Policy applies to all fundraising for all TI bodies, regardless of types of donor or amounts involved, unless otherwise stated in this document. It is to be applied to all new funding from existing donors and to all new donors in the future. It does not apply to income raised from the sale of publications or from fees for participation in conferences, events and other activities. Appropriate care to protect the reputation of TI should always be taken.

Guidelines

Funding to enable TI bodies to carry out their work should be sought from a wide range of sources. Care should be taken to ensure that project-related funding does not result in undue influence over TI's programme work. Subject to maintaining TI's independence and reputation, TI bodies may accept funding from all kinds of sources. Each TI body should list all donations over €1,000 and publicly disclose them, including in the Chapter's Annual Report and on its website, and likewise in the case of TI-S. If there is a significant risk that receiving funds from a particular source would impair TI's independence or if there is a significant risk to TI's reputation from public association with the donor, then funding from that source must not be accepted by a TI body. Any donation to a TI body must be able to stand up to public scrutiny. TI's independence requires that a donor may be subject to the same criticism by TI as any other organisation or individual in a comparable situation. A donor accused of having been involved in corruption can expect no protection from TI.

TI can receive funding from corporations and donors from the private sector. This does not imply any endorsement of a donating company's policies or record. It is advisable that a potential donating company has made a public commitment to ethical standards (such as the UN Global Compact, the Business Principles etc.), and TI bodies may request that corporate donors sign a commitment to integrity before any donation from that company is accepted. No TI body should accept a donation from a company that is found to have engaged in corruption unless the company can demonstrate that this was a violation of the company's policies, that breach of these policies are being addressed in an appropriate manner, or that its policies have been amended to proscribe a similar violation in future. TI works with companies on the understanding that they are working towards a business environment in which bribery is not accepted.

Procedure

It is the responsibility of the staff and Boards of Directors of TI bodies to ensure that TI's independence and reputation are not jeopardised. The procedure below describes the steps which should be followed when a staff or Board member believes that any TI body has accepted, or is considering accepting, funding from an inappropriate source. Other people associated with TI may also make use of this procedure.

  • If any staff or Board member of a TI body is concerned that there is a threat to TI's independence or reputation from donations already received, or about to be accepted, the person(s) should draw this to the attention of their manager or the Chair of the Board of that particular TI body.
  • If necessary, the manager or Chair of the body will consult with the Fundraising Task Force of the TI Board to seek advice on whether to accept funding from a specific donor.
  • If any TI body proposes to accept more than €100,000 (or an amount greater than 20% of its overall budget) from any private company in a year, this should be brought to the attention of the TI Board Fundraising Task Force for their advice.
  • All communications with the Fundraising Task Force of the TI Board should be made through a TI Board member or the Chief Executive of TI-S. The Fundraising Task Force will report to the TI Board all guidance given under this procedure.

TI-UK Policy on anonymous donations

The TI-UK specific policy on anonymous donations is as follows:

  • Where the anonymous donation is £1,000 or below it is accepted with no follow up. (This section was approved by the TI-UK Board on 28th April 2010 with specific limits of £500 and £5,000. These sums have been adjusted without any further changes.
  • For anonymous donations above £1,000 and below £5,000 TI-UK will require the name and address of the donor in order to establish that donations are from bona fide sources but will keep that name confidential. If such donations come from sources about which we are uncomfortable (e.g. offshore trust accounts etc.) further enquiries will be made. If an anonymous donation is received through the Charities Aid Foundation, no additional verification work needs to be carried out.
  • Anonymous donations of £5,000 and above will require full due diligence.
  • TI-UK recognises that in practice some donors wish to remain anonymous. In such cases, TI-UK should provide the necessary assurance that the donor’s details will only be used to issue a receipt.

 

Annex 3: TI-UK Policy on Conflicts of Interest

Background

Conflicts of interest may arise from time to time in the course of the activities and decisions of persons associated with TI-UK as an employee, consultant or volunteer. These conflicts of interest may arise with regard to pecuniary or financial interests, or other interests that impede them in their duty to act in the best interests of TI-UK and the wider TI movement.

Applicability

This policy applies, except as otherwise stated, to every person associated with TI-UK as an employee, consultant or volunteer. TI-UK Board members and staff are required to adhere to the Code of Conduct for the TI-UK Board (including Annex 2 to the Code, which deals with conflicts of interest) adopted in May 2005 or to any subsequent update.

The activities and associations of family members may also create conflicts of interest or the appearance of conflicts of interest. All board members and senior staff members are expected to declare any such conflicts or potential conflicts as a matter of course. At minimum, they should be declared before any meeting or process, such as a recruitment process, to which the conflict or potential conflict is relevant.

General Policy

Every person associated with TI-UK (as defined above) must avoid or manage any potential, real or perceived conflict of interest (inter alia by refraining from any work or decision making on matters subject to a potential conflict of interest), and openly acknowledge any potential or actual conflict of interest which arises through his/her association with TI-UK.

TI-UK’s efforts to raise the ethical standards of government officials, business people and other individuals could be compromised by any ethical lapses on the part of its staff members. It is essential that everyone associated with TI-UK (as defined above) be highly sensitive to potential conflicts of interest.

How to Deal with a Possible Conflict of Interest

Potential conflicts of interest should be identified and declared by the person in potential conflict, or reported by others as soon as they become aware of such potential conflict of interest. If problems are identified before commitments are made or questionable actions have occurred, embarrassment can be avoided and alternatives can be explored.

Such disclosure or report should be made to the Chief Executive and the Chair of TI-UK’s Board. If the person in potential conflict is the Chief Executive, they should disclose to the Chair of TI-UK’s Board and the Chair of the TI-UK Ethics Advisory Panel.

The evaluation of a potential conflict of interest must be made by the Chief Executive and the Chair of the TI-UK Board. If the person in potential conflict is the Chief Executive, the evaluation must be made by the Chair of the TI-UK Board and the TI-UK Ethics Advisory Panel. The evaluation may determine the absence of a conflict of interest, or it may lead to the conclusion that:

  • the person facing a potential conflict of interest should not go ahead with the evaluated activity, or
  • they should recuse themselves from participating in work or decision-making by TI-UK with reference to the matter in conflict.

The Chief Executive is responsible for ensuring that all persons associated with TI-UK (as defined above) are made aware of the policy and procedures regarding potential conflicts of interest.

 

Annex 4: Procedure for Vetting Clients for Paid Consultancy and Advisory Services


TI-UK’s Business Integrity Programme (BIP) aims to help organisations who genuinely wish to improve their anti-bribery and corruption (ABC) systems.
The vetting process for BIP to decide whether an organisation can be helped is as follows:

  • If the organisation is a Business Integrity Forum (BIF) member or an organisation we have helped recently, we will already have completed a vetting process.
  • For all other organisations, due diligence needs to be conducted prior to commencing any work which may include a questionnaire.

In cases of doubt, the Private Sector Committee of the TI-UK Board will be consulted.


There are a limited number of circumstances where we will not be able to help organisations. These are:

  • We suspect their motivation is not genuinely to improve their ABC systems, but to use TI-UK’s work for PR reasons
  • The organisation has been convicted for bribery or related offences and the board/senior management have made no effort to reform its systems and cannot demonstrate an irrevocable commitment to a strong ABC policy.
  • The organisation is the subject of investigation/legal proceedings for criminal offences in relation to bribery and corruption.
  • The organisation is incorporated in a foreign jurisdiction where a sister TI Chapter has genuine reasons to object to TI-UK working with the organisation
  • There is a conflict of interest with other TI work.

The final decision on whether BIP can help an organisation resides with the TI-UK Board, which has delegated this function to the Private Sector Engagement Committee.
Besides vetting clients, BIP also ensures that any TI-UK employee and external consultants are not conflicted when working on TI-UK projects. We expect any possibility of conflict of interest to be raised at the earliest stage.