Bribery and Corruption

This short article explains our approach to bribery and corruption so that anyone new to these requirements can understand what they mean in practice. 

Definition 

Bribery is defined by the Bribery Act 2010 as offering, giving, receiving, or accepting something of value to influence someone to act improperly, or as a reward for doing so. This might include money, gifts, hospitality, or other advantages, as both financial and non-financial benefits are included. 

TQUK does not tolerate bribery or corruption in any form. Acting ethically is essential, not only to meet legal requirements, but also to maintain trust in our organisation and in the products and services we provide. 

The policy is reviewed each year as part of TQUK’s self-evaluation process taking into account feedback, internal monitoring, regulatory changes, and updates to working practices. In some years, changes are minor; in others, more significant updates may be needed depending on what has changed. 

Responsibilities 

Managers and Team Leaders are responsible for making sure their teams understand the policy and feel confident applying it in their day-to-day work. They are also expected to stay alert to anything that doesn’t seem right so that concerns can be addressed promptly. 

Everyone working for or on behalf of TQUK shares responsibility for avoiding situations where gifts or hospitality could influence decisions, or where it might reasonably be perceived as doing so. 

Gifts

Gifts may only be accepted if they are reasonable, appropriate, and offered openly, with no expectation of influencing a decision. Cash and cash-equivalent gifts (including vouchers) are never acceptable. 

There are occasions where refusing a gift could cause genuine offence or embarrassment. In those cases, the gift may be accepted but must be declared, then either shared with colleagues or donated to charity. All gifts and hospitality, whether offered or received, are recorded in the Gifts and Hospitality Register so they can be reviewed transparently. 

TQUK works with a range of third parties and expects them to meet the same standards that apply internally. Third parties should be aware of this policy, not be involved in corrupt activity, and know whom to contact if they are unsure how it applies. 

Reasonable hospitality that supports positive working relationships is allowed, but it must never be used to influence decisions or behaviour.