Summary

It is GETS policy to conduct all of its business in an honest and ethical manner. GETS takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all our dealings wherever it operates. The Charity also committed to implementing and enforcing effective systems to counter bribery.

 Who is covered by the policy?

This policy applies to all individuals working at all levels, including Charity Trustees, employees (whether permanent, fixed-term or temporary), consultants, contractors, volunteers and any other person providing services to the charity.

 What is a bribe?

A bribe is a financial or other advantage offered or given:

- to anyone to persuade them to or reward them for performing their duties improperly or;

- to any public official with the intention of influencing the official in the performance of his duties.

 Gifts and Hospitality

This policy does not prohibit the giving or receiving of promotional gifts of low value and normal or appropriate hospitality. However, in certain circumstances gifts and hospitality may amount to bribery and all employees must refuse these and raise the issue with one of the Charity Trustees. GETS will not provide gifts or hospitality with the intention of persuading anyone to act improperly or to influence a public official in the performance of his duties.

 Facilitation payments and kickbacks

GETS does not make, and will not accept, facilitation payments or “kickbacks” of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official. Kickbacks are typically payments made in return for a business favour or advantage.  All persons representing GETS must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.

 Donations

GETS does not make contributions of any kind to political parties. No charitable donations will be made for the purpose of gaining any commercial advantage.

 Record Keeping

GETS will keep financial records in place which will evidence the business reason for making any payments to third parties.

All expense claims relating to hospitality, gifts or expenses incurred to third parties must be submitted in accordance with GETS expenses policy and any such claims must specifically record the reason for the expenditure.

Individuals are expected to record any significant gifts or incentive payments that they receive.

 Raising Concerns

Employees and others representing GETS will be encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. No employee will suffer any detriment as a result of raising genuine concerns about bribery, even if they turn out to be mistaken.

 Monitoring

The effectiveness of this policy will be regularly reviewed by the Charity Trustees.  Internal control systems and procedures will be subject to audit under the internal audit process.

 Communicating this Policy

All people representing GETS will be made aware of this policy, which is also available on the Charity’s Web site for public inspection.