Donations, Hospitality and Anti-Bribery Policy

Summary

The purpose of this policy is to help employees and persons working on behalf of or associated with Didcot Train (“TRAIN”) to understand what to do if they are offered gifts and hospitality, and to provide a clear framework to ensure that all relevant parties understand what constitutes bribery, corruption, or exposes TRAIN to accusations (founded or unfounded) of unethical or unlawful behaviour.

Implementation

This policy will be disseminated to Trustees, employees, and volunteers (collectively referred to as “Members”) via the electronic filing system and access to a google shared drive.

1. Introduction

1.1 Didcot TRAIN – Inspiring Young People (TRAIN) is committed to carrying out its business fairly, honestly and openly. We believe that we should not receive benefits of any kind from third parties, which might reasonably be seen to compromise our personal judgement and integrity.

1.2 TRAIN values its reputation for ethical behaviour and financial probity, and reliability. TRAIN recognises that any involvement in bribery is both illegal and will adversely impact its image and reputation.

1.3 This policy applies to all persons working for us or on our behalf in any capacity, including trustees, employees, volunteers, contractors, and external consultants. Note that this policy does not form part of any employee’s contract of employment. It may be amended anytime to adequately deal with any identified risk or in response to regulatory changes.

1.4 This policy aligns with the Bribery Act 2010 (“the Act”). All trustees, employees, and volunteers are required to comply with the Act.

2. Bribery

2.1 A bribe means a financial or other inducement or reward for actions which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.

2.2 Bribery includes offering, promising, giving, accepting or seeking a bribe.

2.3 All staff, volunteers, and other parties, as set out in section 1.3 above, have a responsibility to help in the prevention, detection and reporting of bribery. Specifically, you must not:

• give or offer any payment, gift, hospitality or other benefits in the expectation that a business advantage will be received in return, or to reward any business received.
• accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else.
• give or offer any payment (sometimes called a facilitation payment) to a government or local council official in any country to facilitate or speed up a routine or necessary procedure.
• threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.
• knowingly fail to challenge or report suspicions of bribery or corruption.

3. Gifts or Donations Received by TRAIN

3.1 In deciding whether to accept or decline a donation or gift, TRAIN will consider its best overall interest and will not accept donations from donors whose activities appear to be in direct conflict with our charitable aims and objectives.

3.2 An employee, or any member of their family/friends, should not, directly or through others, solicit or accept money, gifts, hospitality or anything else that could influence or reasonably give the appearance of influencing the relationship with that organisation or individual.

3.3 Unless you have been informed otherwise, you may accept a gift to a nominal value of £15, such as a box of chocolates or biscuits, advertising novelty or small seasonal gift when it is customarily offered to others having a similar relationship with that individual or organisation. It must be made clear to the person or organisation that is giving the gift that the gift will be brought back to the TRAIN office, where a decision will be made as to how to use the gift.

3.4 TRAIN will not take gifts from organisations or individuals who participate in activities which:

• could cause detriment to TRAIN’s reputation.
• will disproportionately decrease the amount of donations to further TRAIN’s work.
• undermine our vision and values.
• are associated with unsuitable products, corporate and individuals, e.g. arms dealings and tobacco.
• are from individuals, groups or organisations known to take advantage of older or vulnerable people.
• are personal gifts to TRAIN staff members, which should be discouraged at all times.
• are from unknown sources of funding. TRAIN will take reasonable steps to determine the ultimate source of funding for each gift and satisfy itself that the funds do not derive, directly or indirectly, from activity that was or is illegal.
• potentially harm our relationships with other donors, service users, stakeholders or volunteers.
• expose us to undue adverse publicity or reputational risk.
• require unacceptable expenditure or additional TRAIN resources.

3.5 If supporters wish to make a donation to a specific area of TRAIN’s work, then they make a specified donation by providing written instruction to this effect with their donation. TRAIN will always respect this. If TRAIN is unable to accept the request for the specified donation and the sponsor does not want the donation used in any other way, TRAIN will refund the donation.

3.6 Refusals of donations or gifts: If a gift is received which may not be acceptable under the terms of this policy, the Treasurer will alert the Trustees at the earliest opportunity so that a decision can be made regarding the donation.

3.7 Donation or gift processing: All donations or gifts must be conveyed to the Treasurer at the earliest possible opportunity accompanied by all original correspondence pertaining to the donation or gift, which will be filed by the Treasurer. A receipt of donation email should also be sent to the Treasurer, detailing the donor’s full name and contact details and address and whether the donation is for restricted or unrestricted funding. If the donation is for restricted funding, the purpose of the donation should also be given.

4. Raising Concerns

4.1 All persons covered by this policy, as set out in 1.3 above, have a responsibility to monitor, prevent and report concerns about a donation or gift that may be a possible breach of this policy. At the earliest possible stage, concerns are to be raised with the Treasurer or the employee’s line manager, who will then escalate to the Chairman. All concerns will be treated confidentially.

5. Training and Communication

Training on this policy forms part of the induction process for all new trustees, employees, and volunteers. Any amendment to the policy will be communicated from time to time to all members. Members will also ensure that contractors, affiliates, and other persons associated with TRAIN with whom they have direct contact are aware of this policy.

6. Monitoring

6.1 The Board of Trustees has the overall responsibility of ensuring compliance with this policy.

6.2 Specifically, the Treasurer is responsible for implementing this policy, monitoring its use and effectiveness, and dealing with any queries that may arise as a result of it.

6.3 The Treasurer will monitor the effectiveness and the implementation of this policy and report any concerns to the Board of Trustees.

6.4 All TRAIN members should also be committed to implementing this policy.