Anti-Corruption and Anti-Bribery Policy
1. Introduction
Sight Loss Ministries is committed to conducting its activities with the highest level of integrity, transparency, and accountability. As a Christian charity dedicated to serving individuals with sight loss, we are opposed to corruption and bribery in all their forms. This policy outlines our zero-tolerance approach towards corruption and bribery and sets out guidelines for our trustees, volunteers and others to follow who are involved with our ministry.
2. Definitions
a) Corruption: Any form of dishonest, unethical, or fraudulent behaviour, including bribery, extortion, embezzlement, abuse of power, and any other illegal or improper practices.
b) Bribery: Offering, giving, receiving, or soliciting anything of value, either directly or indirectly, to influence the actions or decisions of an individual in a position of trust.
3. Compliance with Laws and Regulations
Sight Loss Ministries will comply with all applicable laws and regulations pertaining to anti-corruption and anti-bribery, including the UK Bribery Act 2010. We expect all trustees, volunteers and those involved with our ministry to adhere to these laws and regulations as well.
4. Prohibited Conduct
a) Bribery: No trustee, volunteer, or other person involved with our ministry shall offer, promise, give, request, accept, or receive any bribe, kickback, facilitation payment, or any other form of improper advantage in order to gain an unfair or illegal advantage.
b) Extortion and Blackmail: Sight Loss Ministries will not engage in or tolerate any form of extortion or blackmail, where pressure is exerted to obtain something of value unlawfully.
c) Fraud and Embezzlement: Misappropriation or embezzlement of funds, assets, or resources entrusted to Sight Loss Ministries is strictly prohibited.
d) Corruption: We condemn the abuse of authority or position for personal gain or to exert undue influence over others.
5. Reporting and Whistleblowing
Sight Loss Ministries encourages a culture of transparency and accountability. Any volunteer, partner, or stakeholder who suspects or witnesses corruption or bribery is obligated to report it promptly and confidentially following guidance set out in the organisation’s complaints policy. We will endeavour to protect the confidentiality of whistleblowers and strive to ensure they are not subject to retaliation.
6. Consequences of Non-Compliance
Any individual found to have engaged in corruption, bribery, or any other prohibited conduct will be subject to disciplinary action, which may include termination of employment, termination of partnerships, or legal action, as appropriate. Sight Loss Ministries reserves the right to report suspected or known corrupt activities to the relevant law enforcement authorities.
7. Training and Awareness
Sight Loss Ministries will provide the appropriate training to ensure that all trustees, volunteers and others involved with our ministry understand this policy, recognise corrupt practices, and know how to report any concerns or suspicions.
8. Monitoring and Review
This policy will be regularly monitored, reviewed, and updated to reflect changes in laws, regulations, and best practices related to anti-corruption and anti-bribery. Sight Loss Ministries will also conduct periodic internal audits and/or risk assessments to evaluate compliance with this policy.
9. Record Keeping
The charity keeps detailed financial records, and we have appropriate internal controls in place to evidence the charity's reason for making payments to third parties. All accounts, invoices and other records relating to dealings with third parties – including suppliers and customers – should be completely accurate and transparent.
10. Public Communication
Sight Loss Ministries will communicate its commitment to anti-corruption and anti-bribery practices through its website to promote transparency and accountability.
11. Conclusion
By adhering to this Anti-Corruption and Anti-Bribery Policy, Sight Loss Ministries reaffirms its dedication to ethical conduct, accountability, and the highest standards of integrity. We strive to create an environment that upholds these principles and ensures the responsible stewardship of resources entrusted to us.
Date of last review by the trustee board: 29th June 2023