Last updated: July 2023
1. INTRODUCTION
- A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
- It is Payments Innovation Forum Ltd (“PIF '' or the “Company”) policy to conduct all of our business fairly, openly and honestly. The Company upholds all applicable laws relevant to countering bribery and corruption including but not limited to the UK Bribery Act 2010 (“Bribery Act”).
2. PURPOSE
- The purpose of this policy (the “Policy”) is to set out the Company’s responsibilities, and those working for us, in upholding our position on the prevention of bribery and corruption.
3. SCOPE
- This Policy applies to all directors, officers and employees (“PIF Staff”) of Payments Innovation Forum Ltd.
- This Policy must be read in conjunction with other Company policies, procedures and guidelines, including the PIF Code of Conduct and Competition Law Guidelines.
4. POLICY STATEMENT
- PIF has a zero-tolerance policy towards bribery and corruption and does not accept any level or form of bribery or corruption within the organisation or by any other individual or organisation representing the Company.
- PIF will always seek to take disciplinary and/or legal action against those found to have perpetrated, be involved in, or assisted with improper activities in any of its operations.
- The Company requires PIF Staff to act honestly and with integrity at all times and to safeguard the resources for which they are responsible.
- The Company will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by the laws of the UK, including the UK Bribery Act 2010, in respect of our work at both home and abroad.
- Bribery and corruption are punishable for individuals by up to ten years' imprisonment and/or a fine and if the Company is found to have taken part in, or failed to prevent, corruption it could face an unlimited fine and face damage to our reputation. The Company therefore takes its legal responsibilities very seriously.
- The Company and PIF Staff must comply with the Bribery Act, which makes it a criminal offence to:
- Offer, promise or give a bribe. For the purpose of this Policy, bribe means giving or offering someone a financial or other advantage to encourage that person to perform their functions or activities improperly, or to reward someone for having already done so;
- To request, agree to receive or to accept a bribe, and
- Bribe a foreign public official.
- This Policy strictly prohibits giving or offering anything of value to a government, public body, political party or any of their official advisers or representatives (a “Government Official”), or making payments to third parties, including customers or potential customers, suppliers or other business partners, while knowing or having reason to know that a portion of that payment will be given or promised to such a Government Official.
- This Policy strictly prohibits facilitation payments. For the purpose of this Policy, a facilitation payment is an unofficial payment or other advantage given to a public official to expedite or secure the performance of a routine government action.
- This Policy also strictly prohibits promising, authorising, offering, giving, accepting or soliciting anything of value or any other advantage to any third party, including a customer or potential customer, supplier or other business partner with the intention of influencing or rewarding the recipients’ business decisions.
5. GIFTS
- Subject to clause 4 above, this policy does not prohibit normal and appropriate gifts and hospitality (given and received) such as:
- Gifts openly offered without an intention of influencing the donee to bestow a business advantage upon the donor.
- Gifts which expressly are in accordance with local law.
- Gifts which are clearly appropriate in the circumstances (e.g., a small gift at Christmas time).
- Gifts with a value that is less than the aggregate sum of £500 per donee per annum.
6. RISK AND INTERNAL CONTROL SYSTEMS
- The Company will regularly assess the nature and extent of its exposure to the risks of internal and external bribery and corruption.
- The Company will regularly review and evaluate the effectiveness of its systems, procedures and internal controls for managing the risk of bribery and corruption.
7. INVESTIGATION
- The Company will take all reports of actual or suspected bribery and corruption seriously and investigate proportionately and appropriately any violation or suspected violation of this Policy.
- The Company will not tolerate any form of retaliation for reports or complaints made by PIF Staff in good faith about their suspicion that an actual or potential bribery has taken place, or may take place in the future.
- The Company encourages openness and will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken.
8. RECORD-KEEPING
- The Company keeps financial records and will ensure that it has appropriate internal controls in place which evidence the business reason for making payments to third parties, including suppliers, customers or potential customers or other business partners.
- All accounts, invoices and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, will be prepared and maintained with strict accuracy and completeness.
9. POLICY OVERSIGHT
- The Company’s Board of Directors has overall responsibility for ensuring this Policy complies with the Company’s legal and ethical obligations, and that all those under our control comply with it.
10. POLICY REVIEW
- The Company’s Board of Directors is responsible for reviewing the Policy at least annually to confirm that it remains relevant and is effective in preventing and detecting any form of bribery and corruption, and recommending updates as needed.
This Policy does not form part of any employee's contract of employment and it may be amended at any time.
