Policy: Probity and Anti-Bribery Policy Code: PL007 · 2019. 1. 23. · Ref: PL007 Page 2 of 30 Approved By Group Board: June 2018 Policy: Probity and Anti-Bribery Policy Code: PL007

Revised Policy – Version 3.0 Uncontrolled Copy if Printed

Approved By Group Board: June 2018 Ref: PL007 Page 1 of 30

Policy: Probity and Anti-Bribery

Policy Code: PL007

Business Units: The Community Housing Group & all subsidiaries

Date of Document: June 2018

Date for Next Review: June 2021

Authors: Deputy Group Secretary / Executive Director (Vestia & Corporate Services)

1.0 Policy Statement

1.1 This policy sets out how the Group will endeavour to meet the highest standards

of probity in its dealings and its approach to tackling bribery. 1.2 Our conduct as individuals impacts directly on the Group’s public reputation and

we must all strive to conduct the business in ways that will maintain the good reputation of the sector.

1.3 The Group Board has ultimate responsibility for ensuring the Group maintains the

standards of probity required by the sector. As explained in section 2 below, this responsibility comes from the law, from the expectations of the Group’s regulators and in order to meet recognised best practice in the housing, public and third sectors.

1.4 The Group wishes to carry out its business transparently and fairly and therefore

operates a zero tolerance policy towards bribery by its Board Members, Employees, Contractors, Agents and other Associated Persons. Incidences of bribery could lead to the Group’s reputation being damaged and also lead to deterioration in its relationship with its tenants, customers, business colleagues and other stakeholders.

Introduction

The Community Housing Group Limited (hereafter referred to as the Group) is committed to achieving the highest standards of probity and good governance in all its activities. The Group promotes openness and transparency in all aspects of its work. It expects each of us (as Members, Board Members, committee members, Employees and Volunteers) to practice those principles too.

The Group is committed to eliminating corruption and bribery and achieving the highest standards of good governance in all its activities.




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1.5 As explained below, your conduct can lead to prosecutions being brought against the Group and can impact directly on the Group’s public reputation.

1.6 The Group is committed to avoiding working with other organisations or

individuals who do not commit to doing business without bribery. 1.7 This policy applies to all Board Members, Committee Members, employees and

Involved Residents of the Group at any time. 1.8 All of the people listed above are required by the Group to familiarise themselves

with this policy and associated procedures and to make sure they follow it at all times throughout their relationship with the Group.

1.9 You also need to be aware that this policy applies not only to people who are

directly involved with the Group as Board Members, Committee members, Employees or Involved Residents, but also family members, other close connections and businesses associated with those people. Where you have a family member or a business that is caught by any aspect of this policy it is your responsibility to make sure you disclose your relationship with them, the potential payments or benefits proposed and follow the policy.

1.10 Section 3.20 sets out what happens in the event of a breach and what it would

mean for you. 1.11 Any contractors directly involved in delivering the Group’s business will also be

made aware of this policy and will be expected to comply with it in so far as it would apply to their activities for and on behalf of the Group.

1.12 If we don’t follow the Probity Policy, this can have serious implications for the

Group and the sector including:

• creating legal risks for the Group, for example if the effects of the breach are that the law has been broken or that the procurement regulations have not been followed correctly;

• putting the Group at risk of attracting the (unwelcome) attention of its

regulator(s), who have a range of powers they can use against the Group to sort out problems they perceive with it;

• negatively affecting the reputation of the Group and the sector, for example if

people perceive that there have been “jobs for the boys” or that public money has somehow been “wasted”;

• having serious implications for individuals. If:

o Employees have breached their terms and conditions they can be

disciplined or even lose their jobs;




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o Board Members have breached their duties and responsibilities, they can be personally liable to the Group for any losses or liabilities it suffers as a result;

o Committee Members have breached the Group’s expectations of them

they can be removed or disciplined.

1.13 Therefore it is crucially important that each of us makes sure that we understand and follow every applicable aspect of this policy at all times.

2.0 Legislative and Regulatory Context

2.1 Section 122 of the Housing and Regeneration Act 2008

2.1.1 The Group must comply with section 122 of the Act which relates to the payment

of gifts, dividends and bonuses to Members, former Members, their family members or companies of which they are Directors.

2.1.2 This policy therefore sets out requirements to make sure that the Group complies

with section 122 and (where relevant) general charity law which prohibits benefits being given to Members without express authority to do so.

2.2 Regulatory requirements

2.2.1 The Group has one principal regulator: the Regulator of Social Housing. It is also

currently regulated, in respect of its charitable members, by Her Majesty’s Revenue and Customs.

2.2.2 Under the Charity Commission’s guidance note CC11 (to which the exempt

charities within the Group should have regard), “Trustee expenses and payments”, charities within the Group should only make any payments or benefits where they consider this is in the charity’s best interests and will better help it achieve its purposes. It is also about managing, and being seen to manage, the conflicts of interest which may arise, and being open and accountable to those with an interest in the charity.

2.2.3 Under the Regulatory Framework for Social Housing, Registered Providers

(RPs) must ensure taxpayers’ interests are protected and that the reputation of RPs and the sector generally is not damaged. In particular, the Regulatory Framework says that:

(a) “Registered providers’ boards shall demonstrate to their stakeholders… how they are achieving value for money in delivering their purpose and objectives” (under the value for money standard);




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(b) “Governance arrangements shall ensure they adhere to all relevant legislation…are accountable to tenants, the regulator and relevant stakeholders…safeguard taxpayers’ interests and the reputation of the sector” (under the governance and financial viability standard); and

(c) “Registered providers shall ensure that effective controls and procedures are in place to ensure security of assets and the proper use of public funds” (under the governance and financial viability standard).

2.2.4 It is therefore very important the Group has a robust Probity Policy in place to manage situations where potential conflict of interest or suggestions of bias on the part of decision-makers might arise.

2.3 Best practice

2.3.1 The National Housing Federation (“NHF”) has produced its code of governance,

Promoting board excellence for housing associations and its guidance on standards of conduct Code of Conduct with good practice for members (“the NHF Code”) which, although voluntary, does represent current best practice in the sector. RP’s are recommended to consider it when arriving at their own policies and procedures. In addition, the Regulatory Framework requires RPs to explain any areas of non-compliance with their chosen code of governance.

2.3.2 The NHF Code suggests various procedures an RP may wish to adopt in relation

to payments and the granting of benefits to Employees and Board Members, and makes suggestions as to when certain payments and benefits may or may not be appropriate. It also sets out standards of behaviour to be observed by RPs across a range of issues including on conflicts of interest, payment, gifts and hospitality and openness and confidentiality.

2.3.3 The Code is influenced by the Seven Principles of Public Life, established by the

Nolan Committee on Standards in Public Life. These Principles are:

• Selflessness – as Members, we must make decisions based solely on the mission, vision and values of the Group;

• Integrity – we must not be compromised by outside interests;

• Objectivity – we must remain impartial and ensure choices and decisions are made on merit alone;

• Accountability – we must be responsible for our decisions and actions;

• Openness – wherever possible, we should give reasons for our actions;

• Honesty – we must declare any private interests; and

• Leadership – we must promote these principles by example.




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2.4 The Bribery Act 2010 2.4.1 The Government passed the Act to simplify the law and assist the UK to combat

bribery. The Bribery Act came into force on 1 July 2011 and it applies to the Group and each of its Group Members.

2.4.2 The Act introduced the offences of offering and / or receiving a bribe. It also

places specific responsibility on organisations to have in place sufficient and adequate procedures to prevent bribery and corruption taking place.

2.4.3 Under the Act, “bribery” is defined as “Inducement for an action which is illegal

unethical or a breach of trust. Inducements can take the form of gifts loans, fees rewards or other privileges.” Corruption is broadly defined as the offering or the acceptance of inducements, gifts or favours, payments or benefit in kind which may influence the improper action of any person; corruption does not always result in a loss. The corrupt person may not benefit directly from their deeds; however, they may be unreasonably using their position to give some advantage to another.

2.4.4 To demonstrate that the Group has in place sufficient and adequate

arrangements and to demonstrate openness and transparency, all Board/Committee Members, Employees and Involved Residents are required to comply with the requirements of this policy.

3.0 Policy

Part A: Probity Requirements

3.1 Part A of the policy lists the specific probity requirements that we must observe.

3.2 Payments to Board Members

3.2.1 This section applies to Members, people who have been Board Members at any

time, their family members and companies of which any of these people are Directors.

3.2.2 Section 122 of the Act restricts the Group from making any gift or paying any

dividend or bonus to any of the people listed in paragraph 2.1.1 above. 3.2.3 There are three relevant exceptions to this restriction that are relevant to the

Group, and they can be relied upon as long as these gifts or payments are also permitted by the Constitutions of the Group Members:




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(a) payments of interest due on capital lent to the Group or subscribed in its shares;

(b) payments made to another RP which is an associate or subsidiary of the Group Member; and

(c) payments for the benefit of tenants of the Group Member to assist the tenant to obtain other accommodation by acquiring the freehold or long-leasehold interest in a dwelling.

3.2.4 If a payment is made in breach of paragraph 3.2.2, which does not fall within one of the exceptions in paragraph 3.2.3, the Group Member making the payment has the right under the Act to recover the wrongful gift or payment as a debt from the recipient. The Regulator may also require the relevant Group Member to take action to recover such a wrongful gift or payment.

3.3 Payments to Board/Committee Members and Involved Residents

3.3.1 This section applies to any Board/Committee Member and, where specified, any

Involved Resident. (a) Remuneration

3.3.2 The Group only allows payments and benefits to Board/Committee Members

and Involved Residents under individual contracts for services with Members or as permitted by this policy. Further detail on remuneration is set out in the Board/Committee Member and Involved Residents Remuneration and Expenses Policy.

3.3.3 Such payments and benefits shall only be for services carried out as a

Board/Committee Member and Involved Resident and not for additional services provided to the Group from time to time (which are generally prohibited).

3.3.4 Executive Board Members shall only receive payments and benefits in

accordance with their contract of employment. (b) Expenses

3.3.5 To assist in the proper performance of their duties, the Group may reimburse

Board/Committee Members and Involved Residents for reasonable expenses legitimately incurred in the course of their duties including:

(a) travel costs incurred travelling to and from Board and Committee

meetings and other official functions of the Group which the Group requires the Board/Committee Member or Involved Resident to attend from time to time;




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(b) the costs of a registered childminder looking after the Board/Committee Member or Involved Resident’s child(ren) while they attend meetings or other functions of the Group;

(c) the costs (proportioned to appropriate usage) of installing and maintaining a broadband service to Board/Committee Member’s or Involved Resident’s houses, where required, to enable them to discharge their duties as Board/Committee Members or Involved Residents;

(d) reasonable costs incurred whilst attending external seminars, training sessions or meetings; and

(e) other expenses in line with the appropriate Group policies and procedures on expenses.

3.3.6 Board/Committee Members and Involved Residents must follow the appropriate procedures prescribed by the Group in claiming or reclaiming any expenses they have incurred from time to time. Further detail on reclaiming of expenses is set out in the Board/Committee Member and Involved Residents Remuneration and Expenses Policy.

3.3.7 The Group is under no obligation to pay or repay any expenses claimed by a

Board/Committee Member or Involved Resident who is unable to produce appropriate receipts or other evidence that they have been incurred.

3.3.8 Any disputes or disagreements about expenses from time to time will be

determined by the Chair of the Remuneration & Numerations Committee in his or her absolute discretion, unless the Board Member in question is the Chair of the Remuneration & Numerations Committee, in which case the Chair of the Audit and Assurance Committee will determine the decision.

(c) Indemnity

3.3.9 The Group may indemnify a Board/Committee Member or Involved Resident (or

former holder of these posts) against any expenses incurred by that individual in connection with any civil or criminal proceedings in relation to the Group or any application for relief from liability for negligence, default, breach of duty or breach of trust in relation to the Group.

3.3.10 The Group may not indemnify a Board/Committee Member or Involved Resident

(or former holder of these posts) where:

(a) the Board Member is convicted in criminal proceedings and the conviction is Final;




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(b) a judgment is given against the Board Member and the judgment is Final;

(c) the court refuses (and that refusal is Final) the Member relief in an application for relief; or

(d) that indemnity is in respect of any liability of the Member to pay a fine imposed in criminal proceedings or a sum payable to a regulatory authority as a penalty for non-compliance with regulatory requirements.

3.4 Payments to Employees (a) Remuneration

3.4.1 The Group may make payments of remuneration to Employees where such

payments are due under a contract of employment or are otherwise made in accordance with this policy from time to time.

3.4.2 Remuneration decisions will be made by the Remuneration and Nominations

Committee. All remuneration decisions will be made in accordance with the Group’s published policies on remuneration.

3.4.3 The Group will make remuneration decisions transparently and fairly, in

accordance with the Group’s Constitutions, as appropriate, and remuneration policies from time to time.

(b) Benefits

3.4.4 The Group may only grant benefits of any description to an Employee or

Employees where such benefits are permitted under his/her/their contract(s) of employment, or are otherwise in accordance with this Policy or are approved by the Group Board.

(c) Bonuses

3.4.5 The Group may make bonus payments to an Employee in accordance with the

relevant Employee’s contract of employment or any policy on bonuses approved by the Board from time to time.

3.4.6 Where a bonus payment is proposed which is not in accordance with the

Employee’s contract of employment or an established bonus policy of the Group, it must be approved by the relevant Group Member Board. In deciding whether to approve such a bonus payment, the relevant Group Member Board must consider doing so only on evidence of exceptional performance or in exceptional circumstances.




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3.4.7 Bonuses must not be paid to any Employee who is also a Member or family member of a Member.

3.4.8 Any bonus payments will be made in accordance with comparable levels in the

sector, and having regard to the Group’s obligations as an RP and, as appropriate, as a charity.

(d) Severance and redundancy

3.4.9 For the purpose of this policy, severance payments shall include out of court

settlements in relation to cases referred to the Employment Tribunal. 3.4.10 The Group may make reasonable and fair severance and redundancy payments

to Employees in accordance with its published redundancy and severance policies.

3.4.11 Decisions as to severance and redundancy payments to Employees (except the

Executive Team) shall be made by the Executive Team in accordance with the Group’s redundancy and severance policies. Such payments proposed to be made to senior Employees and the Executive Team shall be decided by the Group Board.

3.4.12 In making a decision as to what is a reasonable and fair level of payment under

paragraph 3.4.10 above, the following considerations shall be taken into account:

(a) the total level of payment due to the Employee contractually, including

pension and notice requirements;

(b) advice from an independent legal advisor and any other suitably qualified persons;

(c) any relevant statutory formula;

(d) any published policies of the Group;

(e) any relevant guidance on best practice;

(f) information on comparable payments made in the sector (if available);

(g) the Employee’s conduct and reasons for departure; and

(h) potential risks to the Group (either by making or not making a

payment), including, in relation to out of court settlement payments for employment disputes, the claim’s prospects of success, the potential legal costs of defending a matter and the effect on the Group if settlement is not made.




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3.4.13 The terms of any severance payment will be included within a properly drawn up compromise agreement or similar document.

3.4.14 The total level of severance and redundancy payments made each year will be

identified in the Group’s annual accounts. 3.4.15 The Group will exercise particular care to avoid any suggestion of secrecy or

impropriety in cases where management failings and/or poor performance or conduct of individual Employees have resulted in the departure of the Employee concerned.

3.4.16 Subject to paragraphs 3.4.4 to 3.4.15 above (inclusive), any non-contractual

payment proposed to be made by the Group to an Employee must be approved by:

• the Chief Executive for Employees who are not members of the

Executive Team; or

• the relevant Group Member Board or a properly authorised committee for the Executive Team.

3.5 Benefit schemes

3.5.1 From time to time the Group may put in place or arrange to participate in benefit

schemes for its Employees, Residents, and/or Board Members with external organisations where such benefits do not require any payment from the Group, such as discount cards for external retail and leisure organisations.

3.5.2 Where such benefit schemes are in place, the Group will publish information

about the schemes, including any eligibility criteria governing an individual’s ability to participate.

3.5.3 If the Group is contemplating awarding a contract for the provision of goods or

services to any external organisation offering a benefit scheme, the fact the organisation offers a benefit scheme to Employees, Residents and/or Board/Committee Members should be declared for the purposes of that contract award procedure.

3.5.4 In accordance with the Group’s Standing Orders, no preferential treatment shall

be given to any external organisation offering such a benefits scheme to the Group’s Employees, Residents and/or Board/Committee Members.

3.5.5 In order to reward or incentivise participation or activity, Group Members may

from time to time decide to make payments or grant benefits to Residents. Any such arrangement should be approved by the relevant Group Member Board and in considering whether to approve such arrangement, the relevant Board shall consider the aims of the arrangement and how the arrangement will




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achieve these, any relevant stakeholder views and any published guidance or norms within the sector. Such arrangements shall be kept under review and no payment may be made which would be in breach of this Policy.

3.6 Ex gratia payments

3.6.1 No ex gratia money payments (other than identified elsewhere within this policy)

may be made to Employees and/or Board/Committee Members or Involved Residents without the prior approval of the Remuneration and Nominations Committee unless in exceptional circumstances as a reward for excellent or long-standing service. Approved ex gratia payments may be made to Employees or Board/Committee Members provided that any such payments do not exceed £200 annually for any one Employee or Board Member. Ex gratia payments will not usually be made to Involved Residents.

3.6.2 Any ex gratia payments made under paragraph 3.6.1 above shall be approved

by the relevant Group Member Board. 3.6.3 The Group will report the total amount of any ex gratia payments in a year within

a report to the Parent Board. 3.7 Gifts made to Board/Committee Members, Employees and Involved

Residents by the Group (a) General Gifts

3.7.1 The Group may make a discretionary allowance of up to £50 per occasion for the

purchase of gifts for Employees, Board/Committee Members and/or Involved Residents subject to the approval of the Executive Team (in the case of Employees) or the Chair of the Remuneration and Nominations Committee (in the case of members of the Executive Team or Board Members), in the following circumstances:

• leaving the Group after 1 year’s continuous service; • maternity leave after 1 year’s continuous service; • retirement; • bereavement; or • any other circumstances approved by the Remuneration & Numerations

Committee/Executive Team (as applicable). 3.7.2 Any allowances for the purchase of gifts paid under paragraph 3.7.1 are subject

to an annual limit of £200 per Employee, Involved Resident or Board Member. 3.7.3 Any allowance paid for the purchase of gifts under paragraph 3.7.1 above which

exceeds the limits set out in paragraphs 3.7.1 and 3.7.2 above or which fall outside the circumstances specified must be approved by the relevant Group Member Board.




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(b) Retirement Gifts 3.7.4 The Group may make a discretionary allowance of up to £200 per occasion for

the purchase of gifts for Employees and/or Board/Committee Members or Involved Residents, subject to the approval of the relevant Group Member Board, where an Employee or Board/Committee Member or Involved Resident is retiring from or leaving the Group following 10 or more years’ continuous service.

(c) Gifts to Members etc.

3.7.5 No allowance may be made for the purchase of gifts, nor may any other gift be

made to any person or organisation which falls within one of the following categories:

• Members, former Members or their family members; or • a company which has a person falling within the bullet point above as a

Director. 3.8 Social events for Board/Committee Members, Employees and Involved

Residents 3.8.1 The Group may provide funding for social events at which Employees,

Board/Committee Members and/or Involved Residents will attend, such as retirement parties and Christmas parties. Any such funding may be provided up to a limit of £50 per Employee, Board/Committee Member and/or Involved Resident per event, within a total annual budget of £200 per Employee, Board/Committee Member and/or Involved Resident.

3.9 Gifts and hospitality

(a) Received from third parties

3.9.1 Board/Committee Members and Involved Residents may, from time to time,

receive hospitality and gifts from external organisations. These may include free gifts (e.g. pens, stationery etc.) or hospitality such as lunches and invitations to social events etc.

3.9.2 Board/Committee Members, Involved Residents and Employees should

generally not receive or offer hospitality and gifts from or to persons or organisations who may be in a position to benefit from actions or decisions taken by the Group.

3.9.3 However, there are circumstances where the acceptance of hospitality or gifts is

in accordance with established business practice, or where the acceptance of gifts is difficult to avoid without causing offence.




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3.9.4 Hospitality should only be accepted by Board/Committee Members, Involved Residents and Employees where:

• it is incidental to the conduct of business or regarded as sustenance;

• the event is in direct furtherance of the Group’s business or linked to the sector; or

• guests include parties other than Board/Committee Members, Involved

Residents and Employees. 3.9.5 Board/Committee Members, Involved Residents and Employees should not

accept hospitality that is particularly lavish or disproportionate to the occasion. This would include hospitality with an estimated value of more than £50.

3.9.6 Board/Committee Members, Involved Residents or Employees may not accept

gifts or hospitality from organisations with which the Group is in dispute or where that organisation is taking part in, or is about to enter into, an active tendering process for a contract with the Group.

3.9.7 The Group will maintain a register of any gifts and hospitality accepted by

Employees and Board/Committee Members and Involved Residents. This register will be audited annually by the Group’s internal auditors, and a report given to the Group Board on the level of gifts and hospitality received.

3.9.8 Any gifts or hospitality accepted up to a value of £10 need not be declared in the

Group’s register of hospitality and gifts, provided that these gifts and hospitality do not exceed an annual limit of £50 from one person or organisation to one Board/Committee Member, Involved Resident or Employee.

3.9.9 Board/Committee Members, Involved Residents and Employees may accept

gifts up to a value of £20, provided that they record the gift in the Group’s register of hospitality and gifts and this does not exceed an annual limit of £100 from any one organisation or person.

3.9.10 Board/Committee Members, Involved Residents and Employees may accept, but

not retain, any gifts with a value from £20 up to £50 where they deem it appropriate, and within the spirit of this policy, to do so. Any such gifts should be notified to the Executive Team and recorded in the register of hospitality and gifts.

3.9.11 Board/Committee Members, Involved Residents and Employees should not

accept gifts with a value of over £50. (b) Provided to third parties

3.9.12 Other than in exceptional circumstances, the Group will not provide hospitality or

gifts to external organisations, other than hospitality with a value of up to £50 per




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person per event, such as catering for a lunch meeting, or commemorative gifts for a function, with a value not exceeding £10 per gift.

3.9.13 Any hospitality or gifts to be provided to external organisations with a cost to the

Group of over £50 per person shall be approved by the Executive Team and with a cost to the Group of over £100 per person shall be approved by the Group Board.

3.9.14 The Group will maintain a register of any gifts and hospitality provided by the

Group to external organisations. This register will be audited annually by the Group’s internal auditors, and a report given to the Board on the level of gifts and hospitality provided.

3.10 Housing of Board/Committee Members, Employees, Involved Residents and

their Family Members 3.10.1 The Group will only house people in accordance with its published allocations

policy. 3.10.2 Relevant Persons will receive equal treatment to all other applicants in the

allocation of housing (including transfer and re-housing applications), and the consideration of an application made by a Relevant Person will be open, fair and transparent.

3.10.3 Any decision to allocate properties, re-house or transfer Board/Committee

Members, Involved Residents, members of the Executive Team and/or their family members and close associates must be approved by the Group Board, and the interest of that Relevant Person must be disclosed.

3.10.4 Any decision to allocate properties, re-house or transfer Employees (other than

members of the Executive Team) and/or their family members and close associates must be approved by the Group Chief Executive and the interest of that Relevant Person must be disclosed.

3.10.5 Any Employee or Board/Committee Member or Involved Resident:

• with an interest in; or • who has a close personal relationship with

a Relevant Person whose application is being considered under paragraphs 3.10.2 to 3.10.4 above will declare that interest and discontinue any involvement they might have in that person’s application.

3.10.6 A payment under a Government home ownership or other similar scheme may

be made to Board/Committee Members, Employees, Involved Residents and their family members or close associates in accordance with the Group’s published criteria for such schemes.




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3.11 Employing Board/Committee Members and Involved Residents and their Family Members and the Family Members of Employees

3.11.1 The Group will carry out all recruitment processes in a way that is rigorous,

transparent and fair. 3.11.2 The Group may offer employment to persons who are family members of the

Group’s Employees, Board/Committee Members or Involved Residents only where it can be demonstrated they are the best candidate for the role.

3.11.3 Where this role is for a senior or Executive Team post, the Remuneration and

Nominations Committee must first approve that decision. 3.11.4 As a general rule where the applicant is a family member or close associate of a

senior Employee, Executive Team Member, Board/Committee Member or Involved Resident there will be a presumption against offering employment.

3.11.5 Where an applicant for a position of employment is a family member or close

associate of an Employee, Board/Committee Member or Involved Resident, this interest must be disclosed by that Employee, Board/Committee Member or Involved Resident.

3.11.6 Any Employee, Board/Committee Member or Involved Resident whose family

member or close associate is applying for a position of employment will not be involved (either directly or indirectly) in the recruitment process for that post.

3.11.7 Subject to compliance with paragraph 3.11.1 above, the Group may offer a

contract of employment to any former Employee. 3.12 Payments to third parties

3.12.1 The Group may not make any payment to:

• a company which is a Member; • a company of which a director is a Member or a former Member; or • a company of which a director is a family member of a Member or former

Member

unless that payment is in respect of interest on capital lent to the Group or subscribed in its shares, or that company is an RP, a Group Member or associate of the Group.

3.12.2 For any other organisation of which a Relevant Person is a Director, the Group

may only make payments or grant benefits (including contracts for the provision of services or goods) where it can be demonstrated the payment or benefit is in the best interests of the Group, following consideration of all other potential contractors.




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3.12.3 Any payment or benefit under paragraph 3.12.2 above must be approved by the Group Chief Executive.

3.12.4 A register must be kept of any payment made or benefit given under paragraph

3.12.2 above, including information as to the Relevant Person and their interest in the company.

3.13 Payments to companies of which Board/Committee Members are also

Employees 3.13.1 Subject to paragraph 3.12.1 above, the Group may make a payment under a

contract for services to a company of which a Board/Committee Member is an employee where it can be demonstrated the payment or benefit is in the best interests of the Group.

3.13.2 Any payment or benefit under paragraph 3.13.1 above must be approved by the

relevant Group Member Board. 3.13.3 A register must be kept of any payment made or benefit given under paragraph

3.13.1 above, including information as to the relevant Board Member. 3.14 Other payments

3.14.1 Any payments made or benefits granted to Relevant Persons which are not set

out as approved within this policy must be approved by the Remuneration & Numerations Committee.

Part B: Probity Procedures 3.15 This section sets out the requirements to ensure that the Group and each

individual complies with the Policy. 3.16 Declaring interests

3.16.1 The Probity Policy requires you to declare certain interests at certain times.

3.16.2 You must make a general declaration of interests at the point you become an

Employee/Board/Committee Member/Involved Resident or at such other times as requested to do so by the relevant Group Member Board or the Compliance Officer. Further information on the need for Board/Committee Members and Involved Residents to make declarations of interest is included in the Code of Conduct for Board and Committee Members and Involved Residents.




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3.16.3 Any interests you declare will be entered onto a Register of Interests which is maintained by the Group Secretary. Any information you provide to the Group in your Declarations from time to time will be held and processed in accordance with the Group’s Data Protection Policy. Subject to this, the Register will be available for inspection by the Group’s regulators and by people with a legitimate interest in the Group and its business from time to time.

3.16.4 You are responsible for making sure your entries in the Register of Interests are

kept up to date. From time to time the Group Secretary will prompt you to check and update your declared interests. However, if you become aware at any time that your interests may have changed or you may have acquired new interests that should be declared, it is your responsibility to ensure that this is done. If there is a breach of the Probity Policy in relation to an interest you should have told us about but didn’t, the Group will treat this very seriously.

3.16.5 As well as making sure that your entries on the Register of Interests remain up to

date, you are responsible for declaring any interests you have in any matter that you are involved in on the Group’s behalf from time to time. For example:

(a) If you are a Housing Officer and one of your family members or close

associates apply to be housed, you must declare an interest and not participate in any decision relating to whether that person can be housed;

(b) If you are a Board/Committee Member and the Board/Committee is

deciding whether to award a contract to a company of which one of your family members is a director, you must declare an interest and withdraw from any discussions and decision-making in relation to that contract;

(c) If you are a member of the Remuneration and Nominations Committee

and your remuneration is the subject for discussion at a committee meeting, you must declare an interest and withdraw from any discussions and decision-making in relation to your remuneration.

These examples are not exhaustive and you must remain vigilant to spot any situations where your personal interests could conflict with those of the Group.

3.17 Other declarations

3.17.1 This policy requires you to declare any hospitality or gifts you are offered or

receive from third parties where the value of the hospitality or gift exceeds £10. 3.17.2 It also requires you to declare any gifts or hospitality offered by or on behalf of

the Group of any value. 3.17.3 As part of its Commercial Strategy, the Group encourages you and your close

family members to use its services




Policy Code: PL007

3.17.4 When requesting a service, you should do so as if you are an external customer and follow the normal customer service request channels for the services you wish to purchase.

3.17.5 At the point of requesting a service, you must also complete a ‘Declaration of

Personal Use and Company Services/Advisors’ form (available on SharePoint or from the Governance Team) and send it to the Group Secretary.

3.17.6 If you are a Board/Committee Member, Involved Resident, Executive Director or

Head of Service, the quote and invoice for your service will be checked and authorised by the Group Secretary/Deputy Group Secretary and the Financial Services Director/Head of Management Accounting to ensure the appropriate charges have been applied (including VAT where appropriate).

3.17.7 For all other employees requesting services, quotes and charges, will be

checked and authorised by the relevant Head of Service and the Head of Management Accounting.

3.18 Using your discretion 3.18.1 From time to time the Policy requires you to use your discretion as to:

(a) whether you need to declare an interest;

(b) whether an interest that has been declared by someone else is relevant;

(c) (where a particular decision is delegated to you to make) whether a particular payment or benefit or other matter covered by this policy should be permitted or not.

3.18.2 Whenever matters are left to your discretion, you need to weigh up the right

decision very carefully to make sure you don’t breach the Probity Policy or put the Group in a difficult situation.

3.18.3 In those circumstances, it is helpful to refer back to the seven Principles of Public

Life listed in section 2 of this policy. You will bear these principles in mind whenever you are called upon to consider or make decisions on any matter that relates to this Probity Policy, whether in your own capacity or that of an Employee, Board/Committee Member or Involved Resident to whom a decision is delegated.

3.18.4 If you need help or support making a decision about anything to do with this

Policy, you should speak with:

• your line manager (if you are an Employee);

• the Group Secretary/Deputy Group Secretary; or




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They will be happy to talk to you in confidence and advise you on the right course of action.

3.19 Delegations

3.19.1 Where the Group Board delegates’ authority to a Committee to make decisions

about any matter contained within this Probity Policy from time to time, it must ensure that such delegation is clear and the committee is of an appropriate size and formality in terms of meetings and record-keeping.

3.20 Breaches of the Probity Policy

3.20.1 For the reasons outlined in section 1 of this policy, compliance with this Policy is

crucial to the Group’s ability to meet its legal, regulatory and best practice requirements. Accordingly, both it and its Regulator will treat any breach of this policy very seriously indeed.

3.20.2 Any alleged breach of this policy will be investigated by the Group.

3.20.3 A breach of this policy by an Employee will be treated as a disciplinary matter

under his or her contract of employment and an appropriate sanction may be applied. An investigation into any allegation of such a breach made against an Employee will be conducted in accordance with the Group’s disciplinary procedures.

3.20.4 A breach of this policy by a Board/Committee Member or Involved Resident will

be treated as a breach of his or her duties and obligations to the Group and his or her services agreement with the Group. An investigation into any allegation of such a breach made against a Board/Committee Member or Involved Resident will be conducted in accordance with the Group’s Code of Conduct for Board and Committee Members and Involved Residents and an appropriate sanction may be applied.

Part C: Anti-Bribery Policy

3.21 The corporate offence

3.21.1 The Bribery Act introduced a strict liability offence for commercial organisations

where someone associated with an organisation (including Board/Committee Members, Employees, Involved Residents, agents or sub-contractors) commits an act of bribery to obtain or retain business or a business advantage.

3.21.2 Strict liability means that the Group may be liable in law without the finding of

fault. At court, it need only be proved that a bribe was made by someone associated with the Group with the intention of giving the Group a business advantage, whether or not the Group encouraged such action or was aware of it.




Policy Code: PL007

The responsibilities under the Bribery Act therefore need to be taken extremely seriously.

3.22 Penalties

3.22.1 Prosecution under the Bribery Act could result in the Group receiving an

unlimited fine and potentially becoming debarred from tendering for public contracts.

3.22.2 Breaches of the Bribery Act could also lead to penalties for the Group’s senior

officers with whose “consent or connivance” bribery was committed. Individuals can be found guilty of bribery and, in the most serious cases, be liable on conviction to imprisonment for up to 10 years, to a fine, or to both.

3.22.3 In addition, individuals could be liable for bribing, receiving a bribe or bribing a

foreign public official. Again, such individuals could be liable on conviction to imprisonment for up to 10 years, to a fine, or to both.

3.23 Adequate procedures – the six management principles

3.23.1 There is a defence to the corporate offence if the Group can show it had

“adequate procedures” in place, designed to prevent bribery. 3.23.2 The Ministry of Justice has issued guidance which sets out six broad

management principles to assist organisations to put in place proper anti-bribery procedures.

3.23.3 The Group will be following these principles to show that it is committed to

eliminating bribery within the Group. 3.23.4 The management principles the Group needs to follow are:

• Proportionality – anti-bribery policies and procedures should be

proportionate to the activities and size of the Group, the sector in which it operates and the risks it faces;

• Top level commitment – establishing a clear culture within the Group in

which bribery is unacceptable;

• Risk assessment – understanding and keeping up to date with the bribery risks it faces by carrying out regular and comprehensive risk assessments;

• Due diligence – the Group needs to know about who it does business

with, who it’s paying money to and why – and make sure the Group’s partners also have reciprocal anti-bribery agreements in place;




Policy Code: PL007

• Communication (including training) – so that all of the Group’s Employees, Board/Committee Members, Involved Residents and business partners know the procedures to follow in situations which may be sensitive to bribery. The Group must ensure that its anti-bribery policies are embedded in the Group’s culture, not just a “box-ticking” exercise; and

• Monitoring and review – through audit and other internal controls the

Group must monitor its anti-bribery procedures to prevent and detect bribery – to make sure its procedures are working!

3.23.5 This policy is designed to address these principles and, primarily, the second key

principle of demonstrating top level commitment and the fifth key principle – having clear, practical and accessible policies and procedures properly communicated to people and organisations with the Group. This policy complements the other procedures the Group has in place to avoid bribery and corruption in the Group.

3.24 Gifts and Hospitality

3.24.1 This section of the policy must be read in conjunction with section 3.9 of this

policy, in particular in relation to approval of levels of gifts and hospitality and the need to record gifts and hospitality.

3.24.2 This policy does not prohibit the giving or receiving of reasonable, proportionate and appropriate hospitality or gifts to or from people and organisations the Group deals with. There are circumstances where the acceptance of hospitality or gifts is in accordance with established business practice, or where the acceptance of gifts or hospitality is difficult to avoid without causing offence. Any such gifts or hospitality should be given openly.

3.24.3 Employees, Involved Residents and Board/Committee Members should

generally not receive or offer hospitality and gifts from or to persons or organisations that may be in a position to benefit from actions or decisions taken by the Group.

3.24.4 Hospitality or gifts cannot be given or received if done so with the intention of

influencing someone to give the Group business, influencing the Group to award business or to reward the provision or retention of business or business advantage.

3.24.5 Any hospitality or gifts given should be reasonable and proportionate and

designed to:

• cement or improve relationships; • show genuine appreciation for services; • improve the Group’s image; and/or • market products or services.




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Recipients should never be given the impression that they are under an obligation to confer a business advantage on the Group because of the gifts or hospitality offered.

3.24.6 Gifts should not be offered to, or accepted from, Government officials or representatives, or politicians or political parties, without the prior approval of the Compliance Officer.

3.24.7 You should never give, promise or offer a payment, gift or hospitality to a

Government official, agent or representative to expedite or “facilitate” a routine procedure (e.g. to speed up a planning application).

3.24.8 If you suspect that hospitality is being offered or provided with an expectation

that a business advantage will be provided by the Group in return, then you must not accept it and you must report this to the Group Secretary immediately.

3.24.9 Any hospitality or gifts offered or received should be declared appropriately.

Unofficial payments or “kickbacks” should not be offered or accepted under any circumstances.

3.25 Expenses

3.25.1 Any expenses claims you make must be in accordance with the Group’s Board/

Committee Member and Involved Residents Remuneration and Expenses Policy, properly recorded and supported by receipts (other than in exceptional circumstances).

3.26 Dealings with third parties

3.26.1 If you make payments to third parties, details of such payments must be properly

recorded and receipted. 3.26.2 In making any such payments, you should consider what these payments are for

and whether they are reasonable and proportionate. 3.26.3 You must make all suppliers/contractors and business partners you deal with

aware that the Group takes bribery and corruption very seriously and that it will not be tolerated.

3.26.4 No hospitality or gifts should be offered to any organisation for which the Group

is tendering for a contract during the tender process. 3.26.5 When entering into a contract with a new supplier/contractor, you must

undertake the appropriate level of due diligence (depending on the value and importance of the contract) to satisfy yourself as to their identity and to ensure that the supplier/contractor has appropriate anti-bribery policies in place. If you are unsure of the process to be followed you should seek guidance from the Compliance Officer.




Policy Code: PL007

3.26.6 You must make sure that all contracts between the Group and third parties contain adequate provisions dealing with anti-bribery and anti-corruption, including the availability of remedies for the Group if an employee of the supplier/contractor is found to be involved in bribery.

3.27 Charitable donations

3.27.1 The Group only makes charitable donations that are legal and ethical. No

donation should be offered or made without the prior approval of the Group Secretary. In making charitable donations there will be an assessment of whether it would be appropriate to make such a donation under a formal grant agreement.

3.28 Political donations

3.28.1 The Group does not make political donations.

3.29 Training

3.29.1 Board/Committee Members, Involved Residents and Employees will receive

training on anti-corruption measures and the requirements of this Policy, and all new Board Members and Employees will receive anti-bribery training as part of their induction.

3.29.2 You must attend any training you are required to attend and, where you cannot

attend a session that has been organised; you must arrange to attend an alternative session.

3.29.3 Any training provided will be monitored and evaluated to ensure it is an effective

method of communicating with Employees and Board Members. 3.30 Advice

3.30.1 You should seek advice from the Group Secretary if you are unsure about how

the provisions of this policy should be applied. 3.30.2 Where appropriate, the Group Secretary should seek legal advice on anti-bribery

issues. 3.31 Practical Procedures

3.31.1 You must make sure that no payments are left unrecorded; to make sure that

there can be no concealment of improper payments.




Policy Code: PL007

3.32 Breaches 3.32.1 If you believe or suspect that a breach of this Policy has taken place, or may

occur in future, for example if a contractor offers you something in return for business, you must notify your line manager / the Group Secretary immediately.

3.32.2 You must tell your line manager/the Group Secretary if you are ever offered a

bribe, suspect that this may happen in the future or if you think you are a victim of another form of unlawful activity.

3.32.3 You must tell your line manager/Group Secretary if you have any concerns or

suspicions that any of your colleagues may be involved in bribery or corruption at the earliest possible opportunity. Alternatively, if you are uncomfortable in doing this, you should raise your concerns or suspicions following the procedure set out in the Group’s Whistleblowing Policy.

3.32.4 The Group is keen to encourage openness and will support you if you raise

genuine concerns you have under this Policy (even if they later turn out to be mistaken). The Group wants to ensure no one suffers detrimental treatment (including disciplinary action or dismissal, threats etc.) because of such reporting or because of refusing to take a bribe. If you feel you have suffered such treatment contact the Group Secretary.

3.33 Examples of Bribery

3.33.1 The following list contains some examples of acts which should set alarm bells

ringing and which should be reported to your line manager/the Group Secretary. These are to give you an idea of the sort of behaviour which is unacceptable and which could have serious consequences.

• You learn that one of the contractors you regularly deal with has a

reputation for paying bribes or requiring that bribes are paid to them.

• A supplier asks you to provide an invoice or receipt when no money is payable or has been paid.

• A supplier insists on being paid in cash and/or refuses to sign a formal

agreement.

• A contractor offers to pay you cash to provide employment for a friend or relative.

• You notice that a Group Member has been invoiced for a payment which

seems large given the service/goods which have been provided.

• You are offered an unusually generous gift or lavish hospitality.




Policy Code: PL007

• You are offered substantially discounted fees for supply of goods to you as a private person.

• You are offered a payment in cash if a contract is awarded to the

contractor/supplier.

Part D: Dealing with Breaches 3.34 This policy is crucial to the Group’s ability to meet its legal requirements.

Accordingly the Group will treat any breach of this policy very seriously indeed. 3.35 Any alleged breach of the policy will be investigated by the Group.

3.36 A breach of the Anti-Bribery Policy by an Employee will be treated as a

disciplinary matter under his or her contract of employment and an appropriate sanction may be applied. An investigation into any allegation of such a breach made against an Employee will be conducted in accordance with the Group’s relevant policies for such investigations. This policy does not form part of any Employee’s contract of employment and it may be amended at any time.

3.37 A breach of the Anti-Bribery Policy by a Board/Committee Member or Involved

Resident will be treated as a breach of his or her duties and obligations to the Group. An investigation into any allegation of such a breach made against a Board Member will be conducted in accordance with the Group’s relevant policies for such investigations and an appropriate sanction may be applied in accordance with Board/Committee Members & Involved Residents’ Code of Conduct, the Group’s Standing Orders and the Group’s Constitutions.

3.38 Where the Group discovers bribery has taken place, it will make a full disclosure

of this to the Serious Fraud Office and co-operate fully in any investigation carried out by the Serious Fraud Office.

3.39 Definitions

3.39.1 The following terms shall have the meanings stated against them within this

policy:

“Act” the Housing and Regeneration Act 2008

“benefit” includes, but is not limited to:

• ex-gratia gifts or benefits;

• the grant of a loan;

• the award of a contract of employment;

• sale of a property for value under right to buy or




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right to acquire;

• the grant of a tenancy or licence;

• the grant of a lease (e.g. shared ownership);

• award of any type of commercial contract (e.g. contract for services).

“Board” the board of management of a Group Member

“Board Member”

means a member of the Board of any Group Member from time to time and includes co-optees

“Bonus” a discretionary payment reflecting good performance under any contract

“Bribery Act” the Bribery Act 2010

“close associate”

someone a member of the public might reasonably think an individual would be prepared to favour or advantage (for example a friend, colleague, neighbour, business associate or someone known though general social contacts)

“Group Secretary/

Deputy Group Secretary”

the Person(s) appointed by the Group Board to oversee this Governance Policy and monitor the Group’s and individual Officer’s and Employee’s compliance with it from time to time

“Committee Member”

means a member of a sub committee of the Group Board and includes co-optees

“Constitution” the rules or memorandum and articles of association of a Group Member

“Employee” a person employed by any Group Member under a contract of employment, including a member of the Executive Team and Executive Board Members

“Executive Team”

the senior management team of the Group, including the Group Chief Executive and other executive directors

“family member”

includes a person’s partner, i.e. their spouse or civil partner or person with whom they live in a




Policy Code: PL007

similar capacity, their parents, grandparents, children, grandchildren, brothers, sisters, uncles, aunts, nephews, nieces and similar relations by marriage or civil partnership; it has a wide meaning to include people who are similar to family members even where there is no relation by birth or law

“Final” for the purposes of paragraph 3.3.10 of the policy, a judgment, conviction or refusal becomes final where (a) the period for bringing an appeal or further appeal has ended; or (b) an appeal is determined, abandoned or otherwise ceases to have effect

“Group” the group of companies and Co-Operative and Community Benefit Societies of which The Community Housing Group Limited is the parent

“Group Member”

“Involved Resident”

any member of the Group, as appropriate

Residents who are involved in delivering or scrutinising the Group’s business activities (for example, members of the Customer Voice and Assurance Group.

“Member” a member/shareholder of any Group Member

“NHF Code” the National Housing Federation’s ‘Code of Conduct with good practice for members’

“Group” means The Community Housing Group Limited

“Regulator” means the Regulator of Social Housing (RSH) or anybody which replaces it or takes over its functions

“Regulatory Framework”

the RSH “regulatory framework for social housing in England”




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4.0 Equality Impact Assessment 4.1 The Group is committed to equal opportunities. An Equality Impact Assessment

has been undertaken in respect of this policy to understand the impact that it may have on groups or individuals.

5.0 Performance Measurement and Targets

5.1 The Audit and Assurance Committee will report to the Group Board no less

frequently than every 12 months on the Group’s anti-bribery compliance. 5.2 The key target of this Policy is to ensure the Group meets its regulatory

expectations and requirements and maintains the highest standards of probity whilst also demonstrating a zero tolerance of bribery and corruption.

6.0 Monitoring and Review

6.1 All Board/Committee Members, Involved Residents and Employees are

responsible for ensuring compliance with this policy. The Group Secretary will ensure that all Board Members are aware of the requirements of this policy.

6.2 The Parent Board has overall responsibility for ensuring that all of the Group’s

policies and procedures are kept up to date. It has delegated to the Group Secretary the specific responsibility for maintaining general awareness of and compliance with this policy.

“Relevant Person”

1) any Board Member, Employee, or Involved Resident or any person who, in the preceding 12 months, was a Board Member, Employee or Involved Resident;

2) a Family Member of any person within paragraph 1 above; or

3) a business trading for profit of which a director is a person falling within paragraphs 1 or 2 above.

“Resident” means residents, tenants, leaseholders and service users of Group Members

“RP” Registered Provider of Social Housing as defined in Part 2, Chapter 3 of the Act




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6.3 The Audit and Assurance Committee will monitor the operation and adequacy of this policy on a regular basis and will report to the Group Board on any problems.

6.4 The Company Secretary shall report to the Group Board annually on all entries

made in the hospitality and gifts registers for both Board Members and Employees.

6.5 The Chair of the Audit and Assurance Committee shall be responsible for

examining the hospitality and gifts registers referred to above before they are the subject of the annual report, and shall sign the summary sheet to the registers as a record of what has been declared.

6.6 All Heads of Service (in conjunction with the Head of Human Resources), will be

responsible for ensuring that all staff are trained and are encouraged to contribute suggestions for its continuous improvement, in line with Best Value principles.

6.7 This policy will be reviewed by the Remuneration and Nominations Committee

periodically and no less frequently than every 12 months. It may only be amended with the approval of the Group Board.

6.8 If you have any questions on this policy or any of the issues covered within it,

please contact the Group Secretary. 7.0 Associated Documents / Policies

INTERNAL:

• Governance Framework Document • Employee Terms and Conditions including contracts of employment • Employee handbook • Board/Committee Member & Involved Residents’ role descriptions • Board /Committee Member & Involved Residents’ Code of Conduct • Employees’ Code of Conduct; • Induction pack for Board/Committee Members & Involved Residents • Induction pack for Employees • the Group’s Governance Strategy • the Group’s Scheme(s) of Delegation/Standing Orders and Financial

Regulations and Procurement Arrangements; • Whistleblowing Policy; • Group Members’ Constitutions; • Group Gifts and Hospitality Register;

7.1 Where Part B of this policy (the anti-bribery policy) conflicts with any provision of

the above policies and procedures, Part B of this policy will prevail.




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7.2 The Group will act at all times within the Group Members’ Constitutions. If anything within this policy conflicts with the Constitutions, the Constitutions will take priority.

EXTERNAL: • National Housing Federation, Code of Conduct • National Housing Federation Code- Promoting board excellence for housing

associations (2015) • Bribery Act 2010 • Equality Act 2010 • Human Rights Act 1998

APPENDIX:

• Form of declaration of a gift / hospitality (Board/Committee Members and

Involved Residents and employees)

Policy: Probity and Anti-Bribery Policy Code: PL007Business Units: The Community Housing Group & all subsidiaries Date of Document: June 2018

1.0 Policy StatementPolicy: Probity and Anti-Bribery Policy Code: PL007Policy: Probity and Anti-Bribery Policy Code: PL007

2.0 Legislative and Regulatory Context2.1 Section 122 of the Housing and Regeneration Act 20082.2 Regulatory requirements2.3 Best practicePolicy: Probity and Anti-Bribery Policy Code: PL0072.4 The Bribery Act 2010

3.0 PolicyPart A: Probity Requirements3.2 Payments to Board Members3.3 Payments to Board/Committee Members and Involved Residents(a) Remuneration(b) ExpensesPolicy: Probity and Anti-Bribery Policy Code: PL007(c) Indemnity

Policy: Probity and Anti-Bribery Policy Code: PL0073.4 Payments to Employees(b) Benefits(c) Bonuses

Policy: Probity and Anti-Bribery Policy Code: PL007(d) Severance and redundancy

Policy: Probity and Anti-Bribery Policy Code: PL0073.5 Benefit schemes

Policy: Probity and Anti-Bribery Policy Code: PL0073.6 Ex gratia payments3.7 Gifts made to Board/Committee Members, Employees and Involved Residents by the Group

Policy: Probity and Anti-Bribery Policy Code: PL007(b) Retirement Gifts(c) Gifts to Members etc.3.8 Social events for Board/Committee Members, Employees and Involved Residents3.9 Gifts and hospitality

Policy: Probity and Anti-Bribery Policy Code: PL007(b) Provided to third parties

Policy: Probity and Anti-Bribery Policy Code: PL0073.10 Housing of Board/Committee Members, Employees, Involved Residents and their Family Members

Policy: Probity and Anti-Bribery Policy Code: PL0073.11 Employing Board/Committee Members and Involved Residents and their Family Members and the Family Members of Employees3.12 Payments to third parties

Policy: Probity and Anti-Bribery Policy Code: PL0073.13 Payments to companies of which Board/Committee Members are also Employees3.14 Other paymentsPart B: Probity Procedures3.16 Declaring interests

Policy: Probity and Anti-Bribery Policy Code: PL0073.17 Other declarations

Policy: Probity and Anti-Bribery Policy Code: PL0073.18 Using your discretion

Policy: Probity and Anti-Bribery Policy Code: PL0073.19 Delegations3.20 Breaches of the Probity PolicyPart C: Anti-Bribery Policy

Policy: Probity and Anti-Bribery Policy Code: PL0073.22 Penalties3.23 Adequate procedures – the six management principles

Policy: Probity and Anti-Bribery Policy Code: PL0073.24 Gifts and Hospitality

Policy: Probity and Anti-Bribery Policy Code: PL0073.25 Expenses3.26 Dealings with third parties

Policy: Probity and Anti-Bribery Policy Code: PL0073.27 Charitable donations3.28 Political donations3.29 Training3.30 Advice3.31 Practical Procedures

Policy: Probity and Anti-Bribery Policy Code: PL0073.32 Breaches3.33 Examples of Bribery

Policy: Probity and Anti-Bribery Policy Code: PL007Part D: Dealing with Breaches3.39 Definitions

Policy: Probity and Anti-Bribery Policy Code: PL007

5.0 Performance Measurement and Targets6.0 Monitoring and ReviewPolicy: Probity and Anti-Bribery Policy Code: PL007

7.0 Associated Documents / PoliciesINTERNAL:EXTERNAL:APPENDIX: