It is SSAFA policy to conduct all of our activities in an honest and ethical manner, and to implement and enforce effective systems to counter fraud, bribery and corruption. We will uphold all relevant laws; however, we remain bound by the laws of the UK, including the Fraud Act 2006 and Bribery Act 2010, in respect of our conduct both at home and abroad.

Fraud, bribery and corruption are punishable for individuals and organisations. Individuals face up to ten years in prison and SSAFA, if found to have taken part, could face an unlimited fine and be excluded from tendering for public contracts. We therefore take our legal responsibilities very seriously.

Any concerns raised will be swiftly investigated and appropriate action taken, including working with the police or other relevant authorities.

A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. The offer and acceptance of a bribe are criminal offences and unacceptable under this policy. We do not make and will not accept facilitation payments or ‘kickbacks’ of any kind. However, this does not prohibit normal and appropriate hospitality (given and received) to or from third parties.

Events arranged to thank and encourage donors would not constitute a bribe provided that the intention of the event was to educate the donors about SSAFA’s work rather than improperly to influence their decision through lavish hospitality and gifts. Specifically, the giving or receipt of a gift is not prohibited if the following requirements are met:

• it is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
• it complies with the law;
• it is given in our name, not in the name of an individual;
• it does not include cash or a cash equivalent (such as gift certificates or vouchers);
• it is appropriate and proportionate in the circumstances;
• taking into account the reason for the gift, it is timely and of suitable type and value;
• it is given openly, not covertly;
• it should not be offered to or accepted from government officials or representatives without the prior approval of Chief Operating Officer (COO) at Central Office.

It is appreciated that the practice of giving gifts varies between regions and sectors; what may be normal and acceptable in one region or sector may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.

We keep financial records and have appropriate internal controls that provide evidence of the business reasons for making payments to third parties. All accounts, invoices, memoranda, other documents and records related to dealings with third parties, including all hospitality or gifts accepted or offered with a monetary value of more than £50 are recorded and subject to managerial review. All accounts are prepared with strict accuracy and completeness; no account must be kept ‘off-book’ to facilitate or conceal improper payment(s).

SSAFA Council and the boards of directors of its trading subsidiaries have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control observe them.

The Management Board, through directors and heads of departments, has primary day-to-day responsibility for implementing this policy, and for regularly reviewing its suitability, adequacy and effectiveness. Any improvements identified will be implemented as soon as possible through the COO, Regional/Branch/Service Committee Chair and managers at all levels are responsible for ensuring their volunteers and staff are made aware of, understand and comply with the policy.

It is not acceptable for you (or someone on your behalf) to:

• give, promise to give or offer a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
• give, promise to give or offer a payment, gift, or hospitality to a government official, agent or representative to ‘facilitate’ or expedite a routine procedure;
• accept payment from a third party that you know or suspect is offered with the expectation that it will obtain business advantage for them;
• accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return;
• threaten or retaliate against someone who has refused to commit a bribery offence or who has raised concerns under this policy; or
• engage in any activity that might lead to a breach of this policy.

We do not make and will not accept facilitation payments or kickbacks of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine action by a government or other official; kickbacks are typically payments made in return for a business favour or advantage.

If you are asked to make a payment on behalf of SSAFA, you should always be mindful of what the payment is for, and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt setting out the details of the reason for the payment.

If you have any suspicion, concern or query regarding a payment you should raise it with your Regional/Branch/Service Committee Chair or Director of Volunteer Operations at Central Office, who may in turn consult with the COO. Everyone must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.

You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those volunteering or working for SSAFA or under SSAFA control.

You must inform your Regional/Branch/Service Committee Chair or Director of Volunteer Operations as soon as possible if you believe or suspect that there has been a conflict with this policy or that such conflict may occur in the future, for example if a donor or potential donor offers you funding to gain a business advantage with us, or indicates to you that a gift is required to secure their funding.

The following is a list of possible risks that may arise in the course of your volunteering for SSAFA, raising concerns under anti-bribery and corruption laws. The list is for illustrative purposes and is not intended to be exhaustive; if you encounter any of these situations you must report them promptly to your Regional/Branch/Service Committee Chair or Director of Volunteer Operations:

1. you become aware that a third party engages in, or has been accused of engaging in, improper business practices;
2. 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 government officials;
3. 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 function or process for us;
4. 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;
5. a third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business;
6. a third party requests an unexpected additional fee or commission to ‘facilitate’ a service;
7. a third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services;
8. a third party requests that a payment is made to ‘overlook’ potential legal violations;
9. a third party requests that you provide employment or some other advantage to a friend or relative;
10. you receive an invoice from a third party that appears to be non-standard or customised;
11. a third party insists on the use of side letters or refuses to put terms agreed in writing;
12. you notice that we have been invoiced for a commission or fee payment that appears large given the service stated to have been provided;
13. 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;
14. you are offered an unusually generous gift or lavish hospitality by a third party.

Gifts offered with a value of more than £50 must be discussed and approved by your Regional/Branch/Service Committee Chair or Director of Volunteer Operations before they are accepted. There may be exceptions to this rule where refusal to accept the gift immediately would cause extreme embarrassment to the giver and/or SSAFA, in which case the gift should be reported as soon as possible. It will then be decided if the gift can be retained or if it should be used in some other way. If in doubt, advice should be sought from COO.

As a general rule, perishable goods should be shared among the whole team, and gifts above minimal value should be raffled off at the earliest opportunity with the proceeds going to SSAFA.

Any volunteer who breaches this policy will face action that could result in termination of SSAFA membership. Disciplinary action for SSAFA employees is covered in our Employee Handbook.

You must report to your Regional/Branch/Service Committee Chair all hospitality or gifts accepted or offered with a monetary value of more than £15. The reason for any expenditure relating to hospitality, gifts or expenses incurred to third parties must be specifically recorded when the claim is submitted.

All accounts, invoices, memoranda, other documents and records relating to dealings with third parties such as clients, suppliers and business contacts should be prepared and strictly maintained with accuracy and completeness; no account must be kept ‘off book’ to facilitate or conceal improper payments.

You are encouraged to raise concerns about any issue or suspicion of malpractice as soon as possible. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other query, it should be raised with your Regional/Branch/Service Committee Chair or Director of Volunteer Operations.

SSAFA will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. All concerns raised will be treated seriously and in confidence. For further information see our Whistleblowing Policy; for free, confidential legal advice contact , Protect Speak up, stop harm, the whistleblowing charity, on 020 3117 2520 (https://protect-advice.org.uk).