Anti-Bribery And Corruption


Introduction: Derbyshire House conducts all of its business in an honest and ethical manner.  We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our dealings and relationships.

It is a criminal offence to offer a promise of or provide or request or accept a bribe. It is an offence for us to fail to prevent an incident of bribery committed either by ourselves or by someone associated with the home in order to obtain or retain a business advantage. Derbyshire House operates a strict no tolerance policy towards bribery in all its forms whether directly or through third parties.

This anti-bribery and corruption policy applies to all members of staff, full and part-time employees, temporary staff and directors. Any breach of this policy will be regarded as a serious matter by Derbyshire House and is likely to result in disciplinary action. The staff are required to read and understand all aspects of this policy and abide by it.

This policy does not form part of any employee’s contract of employment and we may amend it at any time. It will be reviewed regularly.

What is bribery and corruption? Bribery and corruption can occur in many forms. Understanding and recognising when they might occur is a key step in guarding against them.

Bribe  means a financial or other inducement or reward for action 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.

Bribery is the offer, promise, giving, demanding or acceptance of a bribe.

All forms of bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it with your manager.

Specifically, you must not

  • give or offer any payment, gift, hospitality or other benefit 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 official in any country to facilitate or speed up a routine or necessary procedure;

Corruption is the misuse of public office or power for private gain; or misuse of private power in relation to business outside the realm of government

Gifts and Hospitality: This policy is not intended to prohibit normal and appropriate hospitality providing it is for legitimate purposes, such as building relationships, maintain our image or reputation, or marketing our products and services.

Gifts, hospitality and entertainment can be bribes if they are intended to influence a business decision. There should be a clear business justification for any hospitality or gift which is funded by the employer or accepted by staff. A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment.  Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers), or be given in secret.

Any high value hospitality or gifts may not be accepted under any circumstances and any such offer should be brought to the attention of the Manager as soon as possible.

The staff at Derbyshire House will not offer or accept gifts of hospitality if the home thinks this might impair objective judgment, improperly influence a decision or create a sense of obligation, or if there is a risk that it could be misconstrued or misinterpreted by others.

Record keeping  All staff must declare and keep a written record of all hospitality or gifts given or received.

Employee Responsibility: The prevention, detection and reporting of bribery is the responsibility of all staff. The employee should be aware of the Whistleblowing Policy .

How to Raise a Concern: If the employee is offered a bribe, or is asked to make one, or if they suspect a violation of this policy, the employee should report this immediately to their line manager or report it in accordance with our Whistleblowing Policy..