What is bribery?
Bribery is an inducement or reward offered, promised or provided to gain personal, commercial, regulatory or contractual advantage. It is a criminal offence.
To use a third party as a conduit to channel bribes to others is a criminal offence. We do not, and will not, engage indirectly in or otherwise encourage bribery.
We are committed to the prevention, deterrence and detection of bribery. We have zero-tolerance towards bribery, and prohibits bribery in any form whether direct or indirect, and by or for the council. We do not, and will not, pay bribes or offer improper inducements to anyone for any purpose, nor do we or will we, accept bribes or improper inducements.
A breach of policies/procedures relating to bribery could lead to disciplinary action.
The Bribery Act
The Bribery Act came in to force 1 July 2011 and may have an impact on the activities of the council.
There are four key offences under the Act:
- bribery of another person (section 1)
- accepting a bribe (section 2)
- bribing a foreign official (section 6)
- failing to prevent bribery (section 7)
The offences carry criminal penalties for individuals and organisations. For individuals, a maximum prison sentence of ten years and/or an unlimited fine can be imposed; for organisations, an unlimited fine can be imposed.
Action
We have reviewed our anti-bribery policy and procedures and need to ensure they are sufficiently robust to prevent bribery and to mitigate the risk of committing a bribery offence. A copy of the policy is attached below.
The further action we take needs to be proportionate to the risk the council is exposed to. We will firstly to carry out an organisation-wide risk assessment. Dependent on those results we can then determine the activity required to implement, review or change procedures so that we comply with the 6 principles laid down in the Act.
- Up-to-date and regular risk assessment
- Procedures proportionate to the risk
- Top-level commitment
- Due diligence
- Communication and training
- Monitoring and review
If you have a concern regarding a suspected instance of bribery or corruption, please speak up – your information and assistance will help. The sooner you act, the sooner it can be resolved, You can raise your concerns through the council’swhistleblowing policy.
Further information
For further information about the Bribery Act and the council’s anti bribery policies please contact Rob Walsh (Strategic Director, Governance and Transformation) or Peter Hanmer (Head of Internal Audit).