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Anti-Bribery and Corruption Policy 2026-08-07T16:12:09+01:00

Anti-Bribery and Corruption Policy

REACH THE CHILDREN UK

Policy Version: 1.0
Effective Date: 3 July 2026
Review Date: July 2027
Approved By: Board of Trustees

1. Policy Statement

Reach the Children UK is committed to conducting all of its activities honestly, ethically and
with integrity. We operate a zero-tolerance approach to bribery and corruption and are
committed to complying with the UK Bribery Act 2010 and all applicable laws in the countries
where we work.

We expect everyone associated with Reach the Children UK to uphold the highest standards
of honesty and transparency in every aspect of our work.

This policy protects the charity, its beneficiaries, donors, volunteers, employees, trustees
and partners from the risks associated with bribery and corruption.

2. Purpose

The purpose of this policy is to:

  • Prevent bribery and corruption in all areas of the charity’s work.
  • Ensure compliance with the UK Bribery Act 2010.
  • Protect the reputation and integrity of Reach the Children UK.
  • Provide clear guidance on acceptable conduct.
  • Promote an open culture where concerns can be raised without fear.

3. Scope

This policy applies to:

  • Anyone acting on behalf of Reach the Children UK including the following : Trustees,
    Employees, Volunteers, Contractors, Consultants, Agents, Suppliers, Partners etc.
    The policy applies both within the United Kingdom and in all overseas activities undertaken
    by or on behalf of the charity.

4. What is Bribery?

Bribery is offering, promising, giving, requesting or accepting anything of value to influence a
person’s actions or decisions improperly.

Examples include:

  • Cash payments
  • Gifts intended to influence a decision
  • Kickbacks
  • Personal favours
  • Excessive hospitality
  • Unauthorised discounts
  • Donations made to obtain improper advantage

Bribery can occur in both the public and private sectors.

5. What is Corruption?

Corruption is the abuse of entrusted power for personal gain.

Examples include:

  • Fraudulent procurement
  • Misuse of charity funds
  • Conflicts of interest
  • Favouritism in awarding contracts
  • Embezzlement
  • False expense claims
  • Misappropriation of donations

6. Zero-Tolerance Commitment

Reach the Children UK will not:

  • Offer or pay bribes.
  • Request or receive bribes.
  • Authorise anyone else to make improper payments on its behalf.
  • Ignore suspected bribery or corruption.

Any individual found to have breached this policy may face disciplinary action, termination of
their relationship with the charity and, where appropriate, referral to the relevant authorities.

7. Gifts and Hospitality

Reasonable and proportionate hospitality may be accepted or offered where it:

  • Supports legitimate business or charitable relationships.
  • Is modest in value.
  • Is transparent.
  • Cannot reasonably be seen as influencing a decision.

The following must never be accepted or offered:

  • Cash or cash equivalents.
  • Lavish entertainment.
  • Gifts intended to influence decisions.
  • Hospitality during procurement or funding decisions.

Where there is any uncertainty, approval should be obtained from the Chief Executive or the
Board of Trustees before accepting or offering a gift or hospitality.

8. Facilitation Payments

Reach the Children UK prohibits facilitation payments.
These are unofficial payments made to secure or speed up routine government or
administrative actions.
If an individual is placed under immediate threat to their personal safety, they should
prioritise their safety and report the incident as soon as possible.

9. Donations and Sponsorship

All donations received and sponsorship arrangements must:

  • Be lawful.
  • Be properly recorded.
  • Not be linked to obtaining improper influence or advantage.
  • Comply with the charity’s financial controls.

10. Procurement and Financial Controls

Reach the Children UK will maintain appropriate controls to reduce the risk of bribery and
corruption by:

  • Obtaining appropriate quotations where practical.
  • Maintaining accurate financial records.
  • Segregating financial duties wherever possible.
  • Ensuring appropriate authorisation of payments.
  • Conducting due diligence on significant suppliers and partners.
  • Monitoring projects and expenditure.

11. Conflicts of Interest

Trustees, employees and volunteers must declare any actual or potential conflicts of interest.
Individuals must not participate in decisions where a personal interest could improperly
influence their judgement.

All declared conflicts will be recorded and managed appropriately.

12. Reporting Concerns

Anyone who suspects bribery or corruption must report their concerns immediately to:

  • The Chief Executive; or
  • The Chair of Trustees if the concern relates to senior management.

Reports will be treated confidentially wherever possible.
No person who raises a genuine concern in good faith will suffer retaliation or disadvantage.

13. Record Keeping

The charity will maintain accurate records of:

  • Income
  • Expenditure
  • Donations
  • Procurement decisions
  • Gifts and hospitality where appropriate
  • Financial approvals
  • False, misleading or incomplete records are prohibited.

14. Responsibilities

Board of Trustees

The Board is responsible for:

  • Approving this policy.
  • Monitoring compliance.
  • Reviewing the policy annually.
  • Promoting an ethical culture.

Chief Executive

The Chief Executive is responsible for:

  • Implementing the policy.
  • Ensuring staff and volunteers understand their responsibilities.
  • Investigating reported concerns.
  • Reporting significant issues to the Board.

Employees and Volunteers

Everyone must:

  • Read and comply with this policy.
  • Avoid situations that could lead to bribery or corruption.
  • Report concerns promptly.
  • Maintain accurate records.

15. Breaches of this Policy

Breaches may result in:

  • Disciplinary action.
  • Removal from volunteering or employment.
  • Termination of contracts.
  • Reporting to law enforcement.
  • Recovery of losses where appropriate.

16. Training

Reach the Children UK will ensure that trustees, employees and volunteers are made aware
of this policy and receive appropriate guidance where necessary.

17. Monitoring and Review

This policy will be reviewed annually by the Board of Trustees or sooner if legislation
changes or operational circumstances require.

Document Control
Policy Owner: Board of Trustees
Approved By: Board of Trustees

Version: 1.0
Approval Date: 3 July 2026
Next Review Date: July 2027