Anti-Bribery Policy
]Anti-Bribery Policy
1. Introduction
The Bribery Act 2010 introduces a new criminal offence of “failure to prevent” bribery, which requires companies to have adequate procedures in place to prevent corrupt practices within their organisations or by third parties acting on their behalf.
Failure to take appropriate action could expose Native Communities to unlimited fines and individuals to prosecution.
2. Policy Overview
Native Communities values its reputation for ethical behaviour and expects all employees to act in accordance with both the letter and the spirit of the legislation.
Breaches of this policy or failure to report such breaches in a timely manner may be considered gross misconduct and could result in summary dismissal.
The purpose of this policy and procedure is to limit Native Communities' exposure to bribery by:
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Setting out a clear anti-bribery policy
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Training all employees and Board members to recognise and avoid bribery
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Encouraging employees to be vigilant and providing appropriate reporting channels
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Rigorously investigating allegations of bribery, and cooperating with the police and relevant authorities
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Taking appropriate disciplinary and legal action against individuals involved in bribery
3. Scope
This policy applies to:
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Board members
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Employees
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Third-party contractors undertaking work on behalf of Native Communities
It is strictly prohibited to:
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Offer, give, solicit, or accept any bribe (cash or other inducements)
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Engage in corrupt behaviour toward any person or company, whether public or private
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Act in a way that seeks to gain commercial, contractual, regulatory, or personal advantage through bribery
4. Acceptable Practices
This policy does not prohibit customary practices that are:
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Normal and appropriate hospitality
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Ceremonial gifts given during festivals or special occasions
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Recognised, legitimate fast-tracked processes available to all upon payment of a fee
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Resources offered to assist a person or organisation in decision-making, provided they are supplied solely for that purpose
All such activities must be proportionate and properly recorded.
5. Responsibilities
Every employee, Board member, and third party acting on behalf of Native Communities must:
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Ensure bribery is treated as unacceptable
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Participate in the prevention, detection, and reporting of any suspected bribery
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Follow the reporting procedure if bribery is suspected
6. Reporting Bribery
If you suspect or have evidence of bribery:
Report the matter in confidence to Helen Stead, Head of People & Culture.
📧 Email: hr@native-communities.com
Reports should be based on reasonable suspicion or evidence, not speculation.
7. Investigation & Disciplinary Action
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A full, thorough, and confidential investigation will be conducted for all reports.
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Appropriate action will be taken against anyone found involved in prohibited activities.
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Procedures will be reviewed to prevent recurrence.
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Malicious or unfounded reports may result in disciplinary action, up to and including dismissal.