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Bribery and corruption

We will not offer, accept, solicit or pay a bribe or facilitation payment.

Even on the smallest scale, corruption is corrosive, and just the suspicion of it can severely damage our reputation.  Remember: we would rather forego business or lose money than become involved in corruption even on the smallest scale.

Sometimes doing wrong can seem right.  For instance, when a small illegitimate payment would prevent a project falling behind schedule, it may seem harmless to pay up. Never be tempted to do so.

Be very cautious when giving or receiving gifts or entertainment. (See "Gifts and Hospitality")

No matter what "local custom" may be, all forms of bribery and corruption, and even the smallest facilitation payment, are forbidden.

Bribery - means giving or receiving an unearned reward to influence someone's behaviour. One common form of bribery is a "kickback" - an unearned reward following favourable treatment. Both are corrupt.

Corruption - is any unlawful or improper behaviour that seeks to gain an advantage through illegitimate means. Bribery, abuse of power, extortion, fraud, deception, collusion, cartels, embezzlement and money laundering are all forms of corruption.

Facilitation Payments - are sums of money paid to an official to speed up or "facilitate" their actions. That's why they are sometimes referred to as "grease" or "speed" payments. Whatever the local custom, Our Code forbids facilitation payments to be made anywhere in the world. We make no distinction between them and bribes, no matter how small the amount.

UK Bribery Act - As a UK based Company we must comply with the UK Bribery Act. It applies to every Serco employee wherever they work around the world, and anyone who works on our behalf. Even if you’re not a UK national and the offence is outside the UK you could be prosecuted, and Serco could receive serious fine and damage to our reputation.

Not sure if it's right or wrong? Check out our SayNo Toolkit and App

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What you can expect from us:

  • We will not participate in any form of corrupt behaviour, either directly or indirectly, anywhere in the world.
  • Under no circumstances will we approve any irregular payment or payment in kind to win business, encourage others to act improperly or influence a decision in our favour.
  • We will not make facilitation payments and we do not allow others who work for us or represent us to make them.
  • Our policy is one of zero tolerance. We may take disciplinary action and, where appropriate, issue criminal proceedings if you give or take bribes, or engage in or condone any form of corruption.
  • We insist that our policy on corruption, bribery and facilitation payments is followed by our business partners, including joint ventures, agents, contractors and suppliers.

We expect you to:

  • Always act with honesty and integrity. Do not participate in any form of corruption or bribery, and do not use others to do so on our behalf.
  • Make sure you are comfortable with the honesty and integrity of any agents representing Serco, and our business partners, contractors and suppliers, and ensure they understand and abide by Our Code.
  • Speak Up immediately if you are concerned or know about any corruption, bribery or facilitation payment involving Serco in any way.
  • Always record and obtain a receipt for all legitimate payments. These are fixed and published fees - for example, to quickly process a visa application - and payment for them should be transparent and open.

Exceptional Circumstances
On very rare occasions you may be coerced into making an illegitimate payment. If you or others are in danger or being threatened, then you should pay. However, you must always record the payment and the circumstances, and report the details immediately to your manager and divisional ethics lead.

Even on the smallest scale, corruption is corrosive, and just the suspicion of it can severely damage our reputation.

No matter what "local custom" may be, all forms of bribery and corruption, and even the smallest facilitation payment, are forbidden.

You have been tasked to deliver a new contract. It's vital it is completed fast. 

The local agent explains that if you are not prepared to pay small sums to various officials, you'll never get the job done. He is not asking for any non-contracted payments for himself.

Should you follow his advice?

1. Even if it's going to hold up the project and it's just a small sum, we must say no

Right answer because:

Sometimes doing wrong can seem right. For instance, when a small illegitimate payment would prevent a project falling behind schedule, it may seem harmless to pay up, especially when such payments are "customary".

However, as our Code makes crystal clear, it is always wrong to do this:

"Facilitation payments are sums of money paid to an official to speed up or "facilitate" their actions. Whatever the local custom, our Code forbids facilitation payments to be made anywhere in the world. We make no distinction between them and bribes, no matter how small the amount."

We insist on this because even on the smallest scale, corruption is corrosive, and just the suspicion of it can severely damage our reputation. We will not participate in any form of corrupt behaviour, either directly or indirectly, anywhere in the world.

So never make the mistake of making a facilitation payment on the grounds that it is helping our business and it's okay because "it's what everyone does round here." It is never okay.

Remember: we would rather forego business or lose money than become involved in corruption even on the smallest scale.

 

2. If it's just petty cash and it will get the job done, there's no harm done

Wrong. Please try again.

3. Yes, he knows the local conditions, what works and what doesn't

Wrong. Please try again.

To get through airport immigration you are asked to pay a small fee in local currency so you can get an entry visa.

Everybody in the queue is paying the fee and there are notices up in the airport about the process.

Should you pay the fee?

1. It depends how much it is

Wrong. Please try again.

2. No, it's a facilitation payment

Wrong. Please try again.

3. Yes, this is okay

Right answer because:

It is acceptable to pay this fee as the process and charges are clearly displayed. This is therefore not a bribe or a facilitation payment.

You can distinguish between a legitimate and illegitimate payment because a legitimate payment is published with a rate card and/or a clear process for payment. However, the payment should not be to an individual.

Here's what Our Code says about this:

"Obtain a receipt and always record all legitimate payments. These are fixed and published fees - for example, to quickly process a visa application - and payment for them should be transparent and open."

In contrast, illegitimate or "facilitation payments" are sums of money paid to an official to speed up or "facilitate" their actions. That's why they are sometimes referred to as "grease" or "speed" payments.

Whatever the local custom, Our Code forbids facilitation payments to be made anywhere in the world. We make no distinction between them and bribes, no matter how small the amount.

 

We are on the verge of winning a new contract. It's a huge opportunity for Serco.

The customer tells us privately that if we donate to a nominated charity, the contract is ours.

Should we?

1. No, under no circumstances

Wrong. Please try again.

2. If it's to a legitimate charity and he's not benefiting, then yes, it's okay

Wrong. Please try again.

3. Almost certainly not, but we could thoroughly check to see if it's possible

Right answer because:

We would need to be extremely careful before making a donation of this kind, and in this context. Here is what our Code says:

"Under no circumstances will we approve any irregular payment or payment in kind to win business, encourage others to act improperly or influence a decision in our favour."

It is hard to see how making this donation could not be seen as doing exactly this.

The problem is that whether the customer means it in this way or not, he has pretty much made this donation a condition of us winning the contract. So this has the potential to be perceived as a bribe, a gift, or a payment in kind to win business - even if the intentions of all parties are innocent, the charity is legitimate, and the customer will not personally gain in any way.

However, the real point here is that in situations like this we must always be very cautious, and always ask if we're not certain. A situation like this needs to be thoroughly checked, handled sensitively and discussed with senior managers.

You learn that one of our partners is giving bribes - but not on our contract.

None of our business?

1. We can't ignore this. We have to address it

Right answer because:

Even on the smallest scale, corruption is corrosive, and just the suspicion of it can severely damage our reputation.

That suspicion can fall on us by association if someone we work with is involved in corrupt behaviour or is giving, receiving or soliciting bribes.

This is why our Code says,

"Speak Up immediately if you are concerned or know about any corruption, bribery or facilitation payment involving Serco in any way."

In this situation, it is your duty to tell us, so the matter can be properly dealt with before any harm is done to our reputation.

Even if you believe reporting the matter would damage our commercial interests, you must always Speak Up when you become aware of a breach of our Code by us, or anyone we are working with.

Our Code always comes before our commercial interests.

2. It's nothing to do with us. We should stay well clear

Wrong. Please try again.

3. We can't do anything, but we should make sure they are not doing this on one of our contracts

Wrong. Please try again.

Dilemma 1

You have been tasked to deliver a new contract. It's vital it is completed fast. 

The local agent explains that if you are not prepared to pay small sums to various officials, you'll never get the job done. He is not asking for any non-contracted payments for himself.

Should you follow his advice?

1. Even if it's going to hold up the project and it's just a small sum, we must say no

Right answer because:

Sometimes doing wrong can seem right. For instance, when a small illegitimate payment would prevent a project falling behind schedule, it may seem harmless to pay up, especially when such payments are "customary".

However, as our Code makes crystal clear, it is always wrong to do this:

"Facilitation payments are sums of money paid to an official to speed up or "facilitate" their actions. Whatever the local custom, our Code forbids facilitation payments to be made anywhere in the world. We make no distinction between them and bribes, no matter how small the amount."

We insist on this because even on the smallest scale, corruption is corrosive, and just the suspicion of it can severely damage our reputation. We will not participate in any form of corrupt behaviour, either directly or indirectly, anywhere in the world.

So never make the mistake of making a facilitation payment on the grounds that it is helping our business and it's okay because "it's what everyone does round here." It is never okay.

Remember: we would rather forego business or lose money than become involved in corruption even on the smallest scale.

 

2. If it's just petty cash and it will get the job done, there's no harm done

Wrong. Please try again.

3. Yes, he knows the local conditions, what works and what doesn't

Wrong. Please try again.

Dilemma 2

To get through airport immigration you are asked to pay a small fee in local currency so you can get an entry visa.

Everybody in the queue is paying the fee and there are notices up in the airport about the process.

Should you pay the fee?

1. It depends how much it is

Wrong. Please try again.

2. No, it's a facilitation payment

Wrong. Please try again.

3. Yes, this is okay

Right answer because:

It is acceptable to pay this fee as the process and charges are clearly displayed. This is therefore not a bribe or a facilitation payment.

You can distinguish between a legitimate and illegitimate payment because a legitimate payment is published with a rate card and/or a clear process for payment. However, the payment should not be to an individual.

Here's what Our Code says about this:

"Obtain a receipt and always record all legitimate payments. These are fixed and published fees - for example, to quickly process a visa application - and payment for them should be transparent and open."

In contrast, illegitimate or "facilitation payments" are sums of money paid to an official to speed up or "facilitate" their actions. That's why they are sometimes referred to as "grease" or "speed" payments.

Whatever the local custom, Our Code forbids facilitation payments to be made anywhere in the world. We make no distinction between them and bribes, no matter how small the amount.

 

Dilemma 3

We are on the verge of winning a new contract. It's a huge opportunity for Serco.

The customer tells us privately that if we donate to a nominated charity, the contract is ours.

Should we?

1. No, under no circumstances

Wrong. Please try again.

2. If it's to a legitimate charity and he's not benefiting, then yes, it's okay

Wrong. Please try again.

3. Almost certainly not, but we could thoroughly check to see if it's possible

Right answer because:

We would need to be extremely careful before making a donation of this kind, and in this context. Here is what our Code says:

"Under no circumstances will we approve any irregular payment or payment in kind to win business, encourage others to act improperly or influence a decision in our favour."

It is hard to see how making this donation could not be seen as doing exactly this.

The problem is that whether the customer means it in this way or not, he has pretty much made this donation a condition of us winning the contract. So this has the potential to be perceived as a bribe, a gift, or a payment in kind to win business - even if the intentions of all parties are innocent, the charity is legitimate, and the customer will not personally gain in any way.

However, the real point here is that in situations like this we must always be very cautious, and always ask if we're not certain. A situation like this needs to be thoroughly checked, handled sensitively and discussed with senior managers.

Dilemma 4

You learn that one of our partners is giving bribes - but not on our contract.

None of our business?

1. We can't ignore this. We have to address it

Right answer because:

Even on the smallest scale, corruption is corrosive, and just the suspicion of it can severely damage our reputation.

That suspicion can fall on us by association if someone we work with is involved in corrupt behaviour or is giving, receiving or soliciting bribes.

This is why our Code says,

"Speak Up immediately if you are concerned or know about any corruption, bribery or facilitation payment involving Serco in any way."

In this situation, it is your duty to tell us, so the matter can be properly dealt with before any harm is done to our reputation.

Even if you believe reporting the matter would damage our commercial interests, you must always Speak Up when you become aware of a breach of our Code by us, or anyone we are working with.

Our Code always comes before our commercial interests.

2. It's nothing to do with us. We should stay well clear

Wrong. Please try again.

3. We can't do anything, but we should make sure they are not doing this on one of our contracts

Wrong. Please try again.