The Hygiene Bank: Anti Bribery and Corruption policy

Overview

This Policy is based on the UK legislation Bribery Act 2010 and sets out The Hygiene Bank’s commitment to upholding sound, responsible and fair business operations and maintaining the highest possible ethical standards in relation to all of its activities. The Hygiene Bank has a zero tolerance towards bribery and corruption and is committed to acting fairly and with integrity in all of its business dealings and relationships.

 

Scope

This Policy applies to staff, contractors, volunteers and Trustees. The Trustees have responsibility for ensuring compliance with this policy. THB procures products from a variety of organisations that host donation collection boxes across the UK, as well as multiple brands in our product supply chain. These products are then passed onto our registered Community Partners. We do not audit the policies and supply chains of our suppliers, as the scale of THB’s operations in comparison to theirs, and the complexity of their supply chains makes it unfeasible.

General principles

What is a bribe?

A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

It is an offence in the UK to:

  • Offer, promise or give a financial or other advantage to another person (i.e. bribe a person) whether within the UK or abroad, with the intention of inducing or rewarding improper conduct.
  • Request, agree to receive or accept a financial or other advantage (i.e. receive a bribe) for or in relation to improper conduct.
  • Bribe a foreign public official. An individual can be held personally liable for any such offence.

Bribery of any kind is strictly prohibited. Under no circumstances should any provision be made, money set aside or accounts created for the purposes of facilitating the payment or receipt of a bribe.

The Hygiene Bank recognises that industry practices may vary from country to country or from culture to culture. What is considered unacceptable in one place may be normal or usual practice in another. Nevertheless, a strict adherence to the guidelines set out in this Policy is expected of all stakeholders at all times.

If in doubt as to what might amount to bribery or other unethical conduct or might constitute a breach of this Policy, you should refer the matter to your Partnership thehygienebank.com | @thehygienebank The Hygiene Bank is a registered charity in England and Wales: 1181267 and in Scotland: SC049895. Manager/line manager who may escalate it to The Board of Trustees, depending upon on the circumstances.

The giving of business gifts is prohibited, unless the following requirements are met:

  • The gift is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage.
  • It complies with local laws
  • It is given in the Charity’s name, not in the giver’s personal name.
  • It does not include cash or a cash equivalent (such as gift vouchers).
  • It is of an appropriate and reasonable type and value and given at an appropriate time.
  • It is given openly, not secretly
  • It is approved in advance by the Board of Trustees.

Essentially, it is not acceptable to give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given, or to accept a payment, gift or hospitality from a third party that you know or suspect is offered or provided with the expectation that it will obtain a business advantage for them.

For the avoidance of doubt, any payment or gift to a public official or other person to secure or accelerate the prompt or proper performance of a routine government procedure or process, otherwise known as a “facilitation payment”, is also strictly prohibited. Facilitation payments are not commonly paid in the UK, but they are common in some other jurisdictions.

Responsibilities and reporting procedure

It is the duty of the stakeholder to take whatever reasonable steps are necessary to ensure compliance with this Policy and to prevent, detect and report any suspected bribery or corruption in accordance with the procedure set out in theWhistleblowing Procedure.

You must immediately disclose to the Charity any knowledge or suspicion you may have that you, or any paid staff, volunteer, Trustee or associated person, has plans to offer, promise or give a bribe or to request, agree to receive or accept a bribe in connection with the business of the Charity. For the avoidance of doubt, this includes reporting your own wrongdoing.

The Charity encourages all stakeholders and partner organisations to be vigilant and to report any inappropriate or unlawful conduct, suspicions or concerns promptly and without undue delay so that investigation may proceed and any action can be taken expeditiously. For example, if a third party offers you something to gain a business advantage with the Charity or indicates to you that a gift or payment is required to secure their business.

In the event that you wish to report an instance or suspected instance of bribery, you should put this in writing (via email) for the attention of the CEO and/or Board of Trustees, to complaints@thehygienebank.com.Confidentiality will be maintained during the investigation to the extent that this is practical and appropriate in the circumstances. The Charity is committed to taking appropriate action against bribery or other unethical conduct. This could include reporting the matter to an appropriate external government department, regulatory agency or the police and/or taking internal disciplinary action against relevant colleagues and/or terminating relationships with partner charities.

The Charity will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken. It is also committed to ensuring nobody suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or corruption offence has taken place or may take place in the future. However, any deliberate or malicious claims will be investigated and dealt with under the Disciplinary Procedure where appropriate.

 

Record-keeping

All accounts, receipts, invoices and other documents and records relating to dealings with third parties must be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off the record” to facilitate or conceal improper payments.

 

Sanctions for breach

Breach of any of the provisions of this Policy will constitute a disciplinary offence and will be dealt with by the CEO and/or Board of Trustees. Depending on the gravity of the offence, it may be treated as gross misconduct and could render the employee liable to summary dismissal. All other persons covered under the scope who breach of this Policy could lead to the suspension or termination of any relevant agreement, contract, sub-contract or other agreement with partner organisations.

 

Examples of potential risks

The following is a non-exhaustive list of possible issues which may raise bribery concerns and which you should report in accordance with the reporting procedure set out above.

  • A third party requests payment in cash, or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made.
  • A third party requests an unexpected additional commission or fee to facilitate a service. A third party demands lavish, extraordinary or excessive gifts or hospitality before commencing or continuing contractual negotiations or provision of services.
  • You are offered an unusually lavish, extraordinary or excessive gift or hospitality by a third party.
  • You receive an invoice from a third party that appears to be non-standard or extraordinary.
  • The Charity is invoiced for a commission or fee payment that appears large given the service stated to have been provided.

 

Policy Review

This policy will be reviewed every two years to ensure that it remains relevant and up-to-date with any changes in data privacy regulations or company practices. The policy may be subject to changes or updates in accordance with applicable legislation and/or best practice requirements. Any updates or revisions to this policy will be communicated to all affected users.

 

Version V.3

Date approved – 14th December 2024

Review date – December 2026