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Anti-bribery & Corruption Policy 

  

Company Name: Teachers Together Ltd (“the Company”) 

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Use: Internal Policy

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Model Policy No.  AB1 

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Model Policy Name: Anti-bribery and Corruption Policy 

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Date: August 2024

 

Version: 2.1

 

 

1. ​Overview

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It is our policy to conduct all of our business in a lawful, honest and ethical manner.

 

We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.

 

Any member of staff who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct with immediate effect.

 

This policy does not form part of any member of staff’s employment contract and we may amend it at any time. It will be reviewed regularly.

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2. Who must comply with this policy?

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This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

 

All staff are expected to act honestly, responsibly and with integrity to safeguard and uphold the Company’s core values by operating in an ethical, professional and lawful manner at all times.

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These behaviours are beneficial to the Company, its reputation and for all who work for it.

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3. What is bribery?  

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Bribe means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.

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Bribery includes offering, promising, giving, accepting blackmailing or seeking a bribe.

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All forms of bribery are unlawful and are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it with your manager.

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Specifically, you must not:

 

  • give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;

  • accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else;

  • give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure;

  • You must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

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4. Gifts and hospitality 

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This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.

 

A gift or hospitality will not be appropriate if it does not comply by local laws, is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).

 

Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include a promise to give or offer of a payment or a payment equivalent (such as vouchers), or be given in secret. Gifts must be given in the Company name, not your name.

 

Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers and business partners.

 

If you are unsure check with your manager.

 

5. Charitable donations

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Bribes may even be disguised as charitable donations.

 

Individuals are free to make any personal donations to charity, however charitable donations should not be made on behalf of the Company without approval first from the Company Director.

 

6. Political contributions

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The Company does not make donations to political parties.

 

If the circumstances are unusual, consult with the Company Director first to obtain their approval.

 

Please consider carefully any donations you make in a personal capacity as some connections could be perceived to impact or harm the Company.

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7. Record keeping  

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You must declare and keep a written record of all hospitality or gifts given or received. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.

 

All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.

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8. How to raise a concern

 

If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify your manager and Company Director as soon as possible who will consider whether the authorities need to be involved.

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If this course of action may not be possible please see the ‘Whistleblowing Policy’ for further details.

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9. Monitoring compliance

 

The Company’s Director has primary responsibility for ensuring company compliance with this Policy.

 

This policy will be reviewed on a regular basis to monitor its effectiveness and ensure it remains up to date with current legislation.

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