ICSA anti-bribery policy

Introduction

The Institute of Chartered Secretaries and Administrators (“ICSA” or the “Institute”) will not tolerate any form of bribery by, or of, its employees, temporary workers, agents or consultants or any person or body acting on its behalf. The Institute and its senior management are committed to implementing effective measures to prevent, monitor and eliminate bribery. For the purpose of this policy, “ICSA” and “the Institute” include subsidiary and associated companies of the Institute.

Any breach of this policy is likely to constitute a serious disciplinary, contractual and criminal matter for the individual(s) concerned, may cause serious damage to the reputation and standing of the Institute and, in certain cases, may lead to the prosecution of the Institute and its senior managers. For employees, any such breach is likely to be deemed gross misconduct.

Purpose and scope
The purpose of this policy is to set out the responsibilities of all Institute staff whether permanent, contract or temporary, within the United Kingdom, the Republic of Ireland and all divisions and territories.

Definitions
“Bribery” means the offering, promising, giving, accepting or soliciting of an advantage as an inducement for an action which is illegal, unethical, or a breach of trust. “Bribes” or “inducements” can take many forms, including but not limited to, gifts, loans, fees, rewards, donations, facilitation payments, and services, travel or accommodation either at a reduced rate or without charge.

A “facilitation payment” is a payment or gift (usually to a government official) to expedite or perform a procedure, but does not include fees required to be paid by law.

Unacceptable behaviour
Employees, agents, consultants or any other person or body acting on the Institute’s behalf must not, in connection with their relationship with ICSA, whether directly or indirectly, accept, request, offer or pay a bribe or inducement.

No employee will suffer demotion, penalty or other adverse consequences for refusing to pay a bribe, even if such refusal results in the Institute losing business or members.

ICSA will take appropriate action wherever it sees the opportunity to stop the practice of facilitation payments or bribery, generally.

If at any time, an employee or representative of the Institute considers themselves under extreme duress and has genuine cause for concern for the welfare and safety of themselves or their family, a facilitation payment may exceptionally be made. Any such payment must be reported at the earliest convenience to the Clerk to Council.

Donations to organisations
“Donation” in this context means any gift, subscription, loan, advance or deposit of money, or anything of value or money’s worth.

The Institute does not make political donations other than to the extent that it may contribute expertise, resources or the time of employees or consultants retained by the Institute, to assist certain groups or organisations concerned with the review of policy, legislation or regulation.

Donations must not be made to any charity or other organisation, directly or indirectly without the prior written approval of the Council or the Chief Executive.

Approval of any donation must be made only in accordance with all applicable laws.

Responsibilities
It is the responsibility of all ICSA employees and any other person or body working on the Institute’s behalf, to seek to prevent, detect, and to report bribery. In the event that bribery is detected, it must be reported without delay, either to one of the named contacts below, or in accordance with the Institute’s Public Interest Disclosure policy, which forms part of the Employee Handbook.

Compliance
All employees are required explicitly confirm they have received a copy of this policy and that they understand it and will comply with it.

The Institute reserves the right to terminate its contractual arrangements with any associated person, at any time, if they are found to be in breach of the Bribery Act 2010.

Contacts
Russell Morrice
Clerk to Council
+44 (0)20 7612 7003
rmorrice@icsa.org.uk

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