Anti-Bribery Policy
Introduction
Wikimedia UK aims at all times to limit its exposure to the risk of bribery and corruption by:
- Setting out a clear Anti-bribery Policy
- Training all employees and contractors so that they can recognise and avoid the use of bribery by themselves and others;
- Encouraging employees and contractors to be vigilant and to report any suspicion of bribery, providing them with suitable channels of communication and ensuring sensitive information is treated appropriately;
- Rigorously investigating instances of alleged bribery and assisting the police and other appropriate authorities in any resultant prosecution;
- Taking firm action against any individual(s) involved in bribery.
Key Principles
- Wikimedia UK is committed to the highest standards of transparency and openness, as described in its mission and values
- Its trustees have made a commitment that integrity and zero-tolerance of bribery are fundamental and non-negotiable
Anti Bribery - Policy
Failure to comply or breach any sections contained within this Anti-Bribery Policy could be regarded as gross misconduct. This may result in dismissal without notice or pay in lieu of notice in accordance with Wikimedia UK's disciplinary procedures.
Bribery is to be understood as defined by sections (1) and (2) of the Bribery Act 2010
The prevention, detection and reporting of potential bribery and corruption is the responsibility of all employees, contractors trustees and volunteers, and they must report any instances of potential bribery and corruption in line with this policy.
Anti-bribery - Responsibilities
Your responsibility in relation to preventing and detecting bribery and/or corruption is as follows:
- To conduct business in line with all appropriate Wikimedia UK policies and procedures including:
- Donation and grant acceptance
- Financial Policy and Procedures
- Access control approval guidelines
- Conflict of Interest Policy
- To be alert to where the Wikimedia UK may be targeted by individuals trying to offer inducements/gifts/loans/rewards or other inducements which may be illegal, unethical or in breach of trust.
- To report any concerns of potential bribery and corruption to a line manager, CEO or Chair of Trustees as deemed most appropriate.
- Staff, contractors, agents or other people associated with the Wikimedia UK must not accept donations, gifts or hospitality above an equivalent value of £25, either on their own behalf or on behalf of Wikimedia UK, without informing and receiving clearance from their line manager.
- The offer by Wikimedia UK employee, contractor or trustee of any gift or inducement to a third party will be dealt with in a similar manner. Where permission has been given for the acceptance of such gifts, a record will be made and kept by the Office and Development Manager of the gift or donation, its value, its donor and its recipient.
- The Audit and Risk Committee will review annually the record of gifts and donations as part of its responsibility for oversight of Wikimedia UK's internal financial controls.
- Bona fide reasonable hospitality or promotional expenditure undertaken to present services or establish or maintain good relations with affiliates (for example invitations to events) or external organizations are not subject to the strictures of this policy.
Raising a concern
Wikimedia UK is committed to creating an open and honest working environment. The reporting procedures in place allow for the choice of the most appropriate route for disclosing genuine concerns. Further information can be found in Wikimedia UK's Whistle blowing Policy.
Annex to Finance Policy
This Policy to become an annex to the WMUK Finance Policy.