The work of AIMS is based on our five key values: Integrity, Empathy, Respect, Collaboration, and Courage. This Policy is designed to help us uphold the key value of Integrity. Each of us is responsible for acting with integrity in everything we do. We can only fulfil our mission to our clients and maintain the trust of our supporters and the public if we act honourably at all times.
AIMS is committed to operating ethically, professionally, fairly, and with integrity in all of its dealings and relationships, and AIMS will comply with all anti-bribery and anti-corruption laws wherever we operate. In the UK, where the charity is registered, the Bribery Act 2010 not only makes bribery and corruption illegal, but will also hold us liable for failing to prevent a bribe being paid on our behalf, no matter where in the world the act takes place.
If AIMS is discovered to have taken part in corrupt activities, we may be subjected to substantial fines and face serious damage to our reputation. Further, individuals involved can be required to pay fines and be sentenced to lengthy jail terms. It is with this in mind that we commit to preventing bribery and corruption, and take our legal responsibilities seriously.
AIMS employees and volunteers are forbidden from paying or receiving bribes or kickbacks.
Bribery is the offering, promising, giving, demanding or acceptance of an advantage as an inducement for an action which is illegal, unethical or a breach of trust. Corruption is the misuse of public office or power for private gain, or misuse of private power in relation to business. Acts of bribery or corruption are designed to influence the individual in the performance of their duty and to incline them to act dishonestly.
Cash is not the only form of bribery. Bribes can take on many different shapes and forms, but typically they involve corrupt intent. There will usually be a 'quid pro quo' – both parties will benefit.
The purpose of this policy is to:
set out the responsibilities of our staff, contractors and volunteers in observing and upholding our position on bribery and corruption, and
provide information and guidance to our staff, contractors and volunteers on how to recognise and deal with bribery and corruption issues.
AIMS employees and volunteers must not provide or receive gifts, meals, entertainment or corporate hospitality where this might result in, or be perceived to result in, an improper advantage.
AIMS employees and volunteers may not provide any gifts or hospitality to third parties without the prior approval of the management team. Any such gift or hospitality must be recorded in writing together with details of the cost, the recipient and the reason for providing it.
AIMS employees and volunteers may not accept any payment or gifts of more than nominal value from third parties in relation to their AIMS role. Payment for work undertaken on behalf of AIMS, for example for participation in a research project, should be made directly to AIMS wherever possible. If this is not possible (for example if PPI partners are rewarded with vouchers) then an equivalent donation to AIMS must be made and recorded as such.
AIMS employees may accept ordinary meals or hospitality if this forms part of a conference, meeting or other event that they are attending on behalf of AIMS, as long as this is appropriate to the circumstances.
Reimbursing a third party's expenses or accepting an offer to reimburse our expenses (for example, the costs of attending a meeting or conference) would not usually amount to bribery. However, a payment in excess of genuine and reasonable expenses (such as the cost of an extended hotel stay) is not acceptable.
AIMS does not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates.
Any charitable contributions that AIMS makes must be allowed under local law, made to or for a bona fide charitable organization, and approved in advance by the management team.
We keep detailed and accurate financial records, and have appropriate internal controls in place to act as evidence for all payments made. We keep a written record of the amount and reason for gifts, meals, hospitality or travel accepted and given, and understand that false, misleading or inaccurate records of any kind could potentially damage the charity.
AIMS employees should raise concerns and must report any suspicious circumstances or violations of this Policy or the law to the management team at management@aims.org.uk as soon as they arise.
Any reports concerning possible improper activity will be dealt with sensitively and treated in confidence to the greatest extent possible.
This Policy applies to all the charity’s employees (staff, contract, and temporary), volunteers, and those AIMS retains to provide us with goods or services.
AIMS Trustees are accountable for the implementation of this Policy.
The AIMS Management Team is responsible for its implementation across the organisation.
The following is a list of possible red flags that may arise during the course of your work for the charity and which may raise anti-corruption risk. The existence of one or more of these (or other) “red flags” does not necessarily mean that corruption has or will occur. The list is not intended to be exhaustive. But you should be aware of any indications of corruption risk. If you feel that corrupt activity has or may occur, do not hesitate to discuss the matter with your team lead, link trustee or the management team (management@aims.org.uk )
You become aware that a third party engages in, or has been accused of engaging in, improper business practices.
You learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a “special relationship” with foreign government officials.
A third party insists on receiving a commission or fee payment before committing to sign up to a contract with us, or carrying out a government function or process for us.
A third party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made.
A third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business.
A third party requests an unexpected additional fee or commission to “facilitate” a service.
A third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services.
A third party requests that a payment is made to “overlook” potential legal violations.
A third party requests that you provide employment or some other advantage to a friend or relative or a person at the third party.
You receive an invoice from a third party that appears to be non-standard or customised.
A third party insists on the use of side letters or refuses to put agreed terms into writing.
You notice that we have been invoiced for a commission or fee payment that appears large given the service stated to have been provided.
A third party requests or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us.
You are offered an unusually generous gift or offered lavish hospitality by a third party.