Anti-Bribery and Corruption Policy

REACH THE CHILDREN UK

Policy Version: 1.0
Effective Date: April 2026
Review Date: April 2027

Approved By: Board of Trustees

1. Policy Statement

Reach the Children UK is committed to conducting its activities with the highest standards of
integrity, transparency and accountability. We are committed to preventing money
laundering, terrorist financing and financial crime in all aspects of our work.
Although charities are generally considered to be at lower risk than financial institutions, we
recognise that charities can be targeted by criminals seeking to disguise the origins of illicit
funds or misuse charitable organisations. Reach the Children UK therefore operates robust
financial controls to minimise these risks and to ensure compliance with all applicable UK
legislation.

2. Purpose

The purpose of this policy is to:
● Prevent the charity from being used for money laundering or terrorist financing.
● Protect the charity’s funds, assets and reputation.
● Ensure compliance with UK legislation and Charity Commission guidance.
● Promote transparency and good financial governance.
● Provide guidance to trustees, employees and volunteers.

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 to all fundraising activities, donations, grants, procurement, overseas
projects and financial transactions.

4. What is Money Laundering?

Money laundering is the process of disguising the criminal origin of money or assets so that
they appear to come from legitimate sources.
Money laundering generally involves three stages:
● Placement – introducing criminal funds into the financial system.
● Layering – moving funds through multiple transactions to conceal their origin.
● Integration – reintroducing the funds as apparently legitimate assets.

5. Risk Areas

Potential risks include:
● Anonymous or unusually large donations.
● Donations from unknown overseas sources.
● Cash donations that appear excessive or unusual.
● Requests for refunds to different bank accounts.
● Transactions that appear unnecessarily complex.
● Pressure to bypass normal financial procedures.
● Payments to unknown third parties.
● Partnerships with organisations that have not been appropriately vetted.

6. Customer and Donor Due Diligence

Reach the Children UK will take reasonable steps to understand the source of significant
donations where appropriate.
The charity may:
● Verify the identity of major donors.
● Carry out due diligence on significant corporate donors and partners.
● Seek clarification regarding unusually large or unexpected donations.
● Decline donations where concerns cannot be satisfactorily resolved.

7. Overseas Partners

As Reach the Children UK works internationally, appropriate checks will be carried out
before entering into partnerships.
These may include:
● Verifying the identity and legitimacy of partner organisations.
● Reviewing governance arrangements.
● Confirming banking details.
● Monitoring how charitable funds are used.
● Maintaining appropriate financial records.

8. Financial Controls

The charity maintains financial controls designed to reduce the risk of financial crime,
including:
● Accurate accounting records.
● Segregation of duties wherever practical.
● Authorised payment approvals.
● Regular bank reconciliations.
● Trustee oversight of financial reports.
● Annual independent examination or audit where required.
● Appropriate documentation supporting all payments.
No payment should be made without appropriate approval and supporting evidence.

9. Cash Handling

Where cash is received:
● Cash should be counted by two individuals where possible.
● Receipts should be issued when appropriate.
● Cash should be banked promptly.
● Accurate records must be maintained.

Cash payments should be kept to a minimum wherever possible.

10. Recognising Suspicious Activity

Examples of suspicious activity include:
● Donations accompanied by unusual conditions.
● Requests to return funds to a different account.
● Donors unwilling to provide information when reasonably requested.
● Unusual payment methods.
● Transactions that appear inconsistent with the donor’s profile.
● Attempts to split payments into smaller amounts to avoid scrutiny.

11. Reporting Concerns

Anyone who suspects money laundering or financial crime must report their concerns
immediately to the Chair of Trustees.
Concerns will be investigated confidentially and, where necessary, external advice or
reporting to the appropriate authorities will be considered.
Individuals raising concerns in good faith will not suffer any detriment.

12. Record Keeping

Reach the Children UK will maintain accurate records of:
● Donations received.
● Grant income.
● Supplier payments.
● Financial approvals.
● Bank transactions.
● Procurement decisions.
● Due diligence undertaken where appropriate.
Financial records will be retained in accordance with legal and regulatory requirements.

13. Responsibilities

Board of Trustees
The Board is responsible for:
● Approving this policy.
● Monitoring compliance.
● Reviewing financial controls.
● Ensuring appropriate oversight of financial risk.

Chief Executive
The Chief Executive is responsible for:
● Implementing this policy.
● Ensuring appropriate financial procedures are followed.
● Reporting significant concerns to the Trustees.
● Arranging appropriate training where required.

Employees and Volunteers
Everyone working with Reach the Children UK must:
● Comply with this policy.
● Follow financial procedures.
● Keep accurate records.
● Report suspicious activity immediately.
● Never knowingly assist money laundering or financial crime.

14. Breaches

Failure to comply with this policy may result in:
● Disciplinary action.
● Termination of employment or volunteering arrangements.
● Removal of trustees where appropriate.
● Reporting to law enforcement or regulatory authorities.

15. Training

Appropriate awareness of this policy will be provided to trustees, employees and volunteers
who handle finances or fundraising activities.

16. Monitoring and Review

The Board of Trustees will review this policy annually, 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
This policy is proportionate for a UK charity of Reach the Children UK’s size