The Bribery Act 2010 defines bribery in a very broad way, namely as a gift or donation intended to “induce a person to perform improperly, a relevant function or activity”. When it comes to any compliance matter, it is important to install a culture whereby all staff feel comfortable raising any concerns they may have, be it regarding the actions of a client, a colleague or a member of the management team. VinciWorks has therefore created a bribery whistleblowing policy template that can easily be edited to suit your organisation and include the appropriate contact people.
What should be included in a whistleblowing policy?
A bribery whistleblowing policy should be aimed at all the staff in your organisation, beginning with an introduction explaining the Bribery Act 2010’s definition of bribery. Here is some brief guidance on what should be included in a bribery whistleblowing policy.
When to use the whistleblowing
This section should explain that whistleblowing is where you have a concern about a danger or illegality that has a public interest aspect to it (e.g. because it threatens clients, third parties or the public). Staff must understand that they should not refer to this policy when they have personal grievances with the organisation or their colleagues.
Procedure for responding to concerns raised
This section should explain which staff member deals with bribery concerns and how the concern will be dealt with. It should also set out the next steps once a concern is raised.
The importance of confidentiality
If a concern is raised against a supplier, it is important to remember that until further investigation is undertaken they are still considered innocent. It is therefore important that the affairs of the supplier are kept confidential. The whistleblower should only divulge relevant information regarding a potential breach of the Act to the appropriate staff member.
Protecting the whistleblower
Any person who victimises a bona fide whistleblower must be liable to disciplinary action. It is important that your policy makes this clear. Whistleblowers should feel comfortable to raise concerns without fearing abuse from their colleagues.
VinciWorks’ anti-bribery resource page
VinciWorks’ anti-bribery resource page shares helpful compliance resources such as course demos, policy templates, helpful articles and guides. You can view the resource page by clicking the button below.
