Anti-Bribery & Corruption

Policy Statement

Scope

Legal Responsibilities

Definitions

Gifts and Hospitality

Facilitation Payments and Kickbacks

Political and Charitable Contributions

Third Parties and Contracts

Raising Concerns and Whistleblowing

What To Do If Offered a Bribe

Training and Communication

Record Keeping

Compliance and Consequences

Monitoring and Review

Last Updated: 18th June 2024

Anti-Bribery & Corruption Policy

Sacana is committed to zero-tolerance against bribery, corruption, and unethical practices. We promote a culture of transparency and integrity.

Policy Statement

Sacana is committed to conducting all business ethically, transparently, and with integrity. We operate a zero-tolerance approach to bribery and corruption and uphold all requirements of the UK Bribery Act 2010 and related regulations.

Scope

This policy applies to all Sacana employees, Matrons, contractors, consultants, volunteers, Board members, suppliers, and partners, covering all Sacana operations both in the UK and internationally.

Legal Responsibilities

Sacana adheres to the Bribery Act 2010, criminalising offering, giving, requesting, or receiving bribes, bribing a foreign public official, and failing to prevent bribery.

Definitions

Bribery: Offering, giving, receiving, or soliciting anything of value to improperly influence decisions.
Corruption: Abuse of entrusted power for private gain.

Gifts and Hospitality

Gifts must be modest, recorded, approved if over £100, and never involve cash or public officials without authorization.

Facilitation Payments and Kickbacks

Facilitation payments and kickbacks are prohibited. If unavoidable for safety, keep amounts minimal, record the incident, and report immediately.

Political and Charitable Contributions

No political donations are allowed. Charitable donations must be legal, transparent, documented, and approved.

Third Parties and Contracts

Contracts must mandate anti-bribery compliance. Due diligence is required before onboarding any third party.

Raising Concerns and Whistleblowing

Report concerns via line manager, Compliance Lead, or confidential whistleblowing channel. No retaliation against whistleblowers.

What To Do If Offered a Bribe

Do not accept or agree. Record full details and report immediately.

Training and Communication

Mandatory training on induction and annually. Third parties are informed during onboarding.

Record Keeping

All gifts, hospitality, donations, and payments must be accurately recorded.

Compliance and Consequences

Breaches may lead to disciplinary action, contract termination, or criminal prosecution.

Monitoring and Review

Policy reviewed annually by Compliance Lead. Contact compliance@sacana.com for concerns.