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Bribery and corruption

We never take or offer any kind of bribe

What it's all about

Where they take hold, bribery and corruption undermine everything – eventually the criminals take over.  So do drug cartels, dishonesty, threats - and violence.  We don’t want to be part of this in any way, shape or form.  If we are seen to be involved, even in the smallest way, it will impact our business and our jobs.  Even just the suspicion of it can do great harm.

That’s why we have zero tolerance. It doesn’t matter how small or harmless it may seem, or what “local custom” may be – we don’t ever give or accept any form of bribery or corruption (including facilitation payments). 

And we’ll report it when we think something could be a bribe or corrupt.

If any of us are caught giving or taking a bribe, we’ll probably face dismissal, the end of our careers and very possibly a prison sentence. But we’ll also do so much harm to our colleagues and to Serco.

“We need the site permits to get the job done. They are demanding a cash payment before they issue them. I know this will go into their pockets. I don’t want to be any part of that.”

What we all need to know and do

  • We are honest people – and we want everyone to trust us for that. We know that even the suspicion of corruption can destroy that trust and do terrible damage.

  • So we never take part in any form of corruption or bribery (including facilitation payments) no matter how small the payment and no matter what ‘local custom’ may be – and we don’t get others to do it for us.

  • We would rather forego business or lose money than become involved in corruption even on the smallest scale.

  • If someone offers or asks us for a bribe, or even if we just hear about it or are worried it might be taking place, we always report it. 

  • We don’t ever let possible corruption or bribery go unquestioned or unreported. 

  • We always record and obtain receipts for every legitimate payment we make. These are fees that are fixed and clearly published – for example, to quickly process a visa application – and payment for them should be transparent and open. 

  • We take the greatest care if we give or receive gifts or entertainment, and always follow our Gifts and Hospitality guidelines.  

  • When we find ourselves working with business partners, agents, contractors, and suppliers, we make sure we’re comfortable with their honesty and integrity, and that they understand and follow the rules of mycode. 

Exceptional Circumstances

  • On very rare occasions you may be coerced into making an illegitimate facilitation payment. If you or others are in immediate 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 and Compliance Lead.

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We’d just won a new contract. It was big news. So we all went out to celebrate, and some of us went on to a club.

The others were dancing. Nia had had too much to drink. So had I. We were sitting in one of those banquettes – you know, where you don’t have to shout over the music. I was talking about how fantastic it was – at last we had a real foothold in a market we’d struggled to get into, and now there were all sorts of possibilities.

‘Yes,’ she said, ‘and we’ll soon make the money back.’

Then she put her hand over her mouth and giggled. ‘Oops! Shouldn’t have said that.’

I asked her what she meant – it didn’t even occur to me what she’d actually say. Like I said, we’d had too much to drink.

‘You know, Michael made sure we’d win.’

“How?’

‘How do you think?’ And she held up her fingers and thumb and rubbed them together.

I think it was then that I started to sober up.

‘What are you saying? He … paid someone?’

‘Of course.’

‘How much?’

‘A lot. Enough.’

Everyone came back from the dance floor then. Michael was trying to tell some funny story above the noise. Then he saw me looking at him and glanced at Nia. I think he knew then.

I didn’t do anything. I thought I’d just be making trouble for everyone, and it was best just to forget about it.

But then one of the directors of the government department we’d got the job with was arrested, and in the end it all came tumbling out.

I hadn’t been involved in Michael’s dirty deal, but I had known, and I hadn’t said anything. So that made me part of it.

I lost my job, along with the others. For months I thought that was unfair. But I don’t anymore. If you know there’s a rotten apple in the barrel you have to take it out. Otherwise the rot goes right through.

If any of us are caught giving or taking a bribe, we’ll probably face dismissal, the end of our careers and very possibly a prison sentence.

But we’ll also do so much harm to our colleagues and to Serco.

We’d been really stretched. Most of us were working extra hours, but there’d been a lot of sickness, and we just couldn’t do all the things we were supposed to.

So we got together and worked out what we could skip, or do on alternate days, so we could still do the important things. 

I think that went on for around three months. And then Ira – she does all the books – came in wanting to know about something that wasn’t making sense. 

No wonder they didn’t. Gene had been filling in the check lists, and had marked as “done” loads of stuff we weren’t doing. All his reports were just totally fake. ‘It’s just till we’re back to normal,’ he said. ‘You want to risk us losing this contract?’

It was an interesting moment. There were some on the team who were really shocked, but there were others who tried to defend Gene, talked about how hard we’d all worked and it wasn’t our fault, we were doing our best and why not just let it go. 

It was Ira who settled things. ‘I am not a dishonest person,’ she said, ‘and I don’t want to work for a dishonest company. Gene, please correct these records and have them on my desk before the end of the day.’ 

With that she went out. Nobody said much, but I think we all knew that if Gene didn’t put things right, Ira would. So of course he did.

I guess that’s the power of one person standing up against something that isn’t right.

We are honest people – and we want everyone to trust us for that. 

We know that even the suspicion of corruption can destroy that trust and do terrible damage.

I was in the washroom when I heard him talking on the phone. He sounded frightened, so I couldn’t help listening. ‘Don’t worry,’ he said, ‘I’ll make sure the payment is with you today.’ 

I thought he was just talking to his bank about sorting out an overdraft. But the next thing he said made me realise this was something very different. ‘Does that mean I’ve got an assurance your officers won’t hold this up? You’d better be telling me the truth!’ 

The next minute was like a scene in a film. I flushed, came out of the cubicle. He looked at me, then ran a tap. So did I. But I had to ask him. ‘Rami, what’s going on? What have you done?’  

‘Making sure we can get this job done on time.’ He just carried on washing his hands and looking at himself in the mirror. 

‘Who are you paying?’

 ‘Don’t be stupid. It’s nothing – a few dollars.’

‘You idiot! It doesn’t matter, it’s a bribe!’

That’s when he turned to me, and the look he gave me – it was one of contempt, like I was a naïve little schoolboy. ‘Come on, man – get real! Haven’t you noticed? It’s what everyone does round here. You really think the company want us to invite any more delays on this project for the sake of a few lousy dollars you and I won’t even notice? Someone has to stand up and do the right thing here. And it looks like I’m the only one prepared to.’

He absolutely believed he was right, and for a moment I wondered if he was too. But then I made my mind up. ‘I’m telling you, Rami - you pay that bribe, and I will report you.’

We probably stared at each other in silence for half a minute. Then he nodded and walked out.

After that we had all sorts of trouble – week after week of local officials making our lives hell and holding things up for the stupidest of reasons. And every time, Rami would give me that look. 

In the end we got that job done, but a few months later we closed the business down. 

I remember telling my boss what happened – wondering if I’d been right to stop Rami, and whether I would really have reported him. And you know what my boss said? ‘If we have to pay bribes to do our business, then it’s not business that’s worth doing. You were right, and he let us down – and if you hadn’t reported him, you would have let us down too.’ 

We never take part in any form of corruption or bribery (including facilitation payments) no matter how small the payment.

It was early morning. We were already on site. I was taking an inventory, when I saw the foreman in the yard, talking to some other guy I’d never seen. 

I saw the guy handing over a small package wrapped in a plastic bag. And the foreman unwrapping the plastic and taking out … money. It must have been quite a bit. 

A couple of days later, that guy was there again – this time unloading maybe ten men from a van. Someone asked who they were. The foreman said they were working for us now. 

I just thought it’s none of my business. But as I watched those men, it didn’t seem right. They looked kind of “done in” – and always kept apart. And that guy would drop them in that van and pick them up every day.

So I just thought I ought to report it. 

Turns out the foreman was taking money from a gang master, and we were employing men who were just being totally exploited. They were literally slaves! 

We don’t ever let possible corruption or bribery go unquestioned or unreported.

‘We’d been waiting for this equipment to arrive for weeks. Without it there was just no way we could continue – and we were already ten days behind. 

So when our manager heard the stuff had come, he asked two of us to go straight to the port to complete the paperwork and get it out of customs. 

We knew what was going to happen – and sure enough it did. 

Customs officer shakes his head, says there’s a problem, he’s not going to be able to release the equipment without “additional checks”. We ask how long that will take. ‘Days,’ he says. ‘Maybe weeks.’  So we ask if there’s any way around that. 

And he says, ‘We can put it on the special fast track for you. Very cheap – one hundred dollars. American. You pay me cash, and you can take your equipment away right now.’

Of course the only fast track system he’s talking about is an illegal $100 cash in hand to him. The fancy word for that is a “Facilitation Payment” – a small little bribe to oil the wheels of commerce. 

Round here you can’t do anything unless you pour a little oil when asked for it. That’s how things work here. But read any Code of Conduct: they all say, ‘Don’t pay.’ 

They have to say that - but they don’t really mean it. I mean, come on - no business really wants you to hold up a whole project just for the sake of $100 nobody’s going to see or miss or hear about. 

So yes, of course we knew it was a bribe. And we knew our manager expected us to pay. And of course we paid. We were thinking of the company.  

It was the right thing to do.’

It’s so easy to see why this person chose to pay that $100. But he was wrong. In every way. 

It wasn’t the right thing to do. 

Even if it’s a tiny sum to avoid what could potentially be a huge and costly hassle for the company, when we say, “Do not pay a facilitation payment”, we really do mean it. 

Why? 

Well, they may just involve small sums, but facilitation payments let corruption and extortion thrive. They destroy jobs, trap the poorest in poverty and withhold services people are entitled to. They undermine fragile societies and human rights. They help criminal gangs and drug cartels control and ruin lives. 

Pay that $100 and that’s what you are doing. And what you are doing on our behalf.

We do not want to be a part of that – and we don’t believe anyone who works for us does either. 

As for the idea that we’ll lose business unless we pay - think about that …

Customers choose Serco because they trust us – and our integrity. If we become known as a company that readily pays corrupt officials or agents, our integrity is gone. And so is the trust others have in us.

Paying a bribe, no matter how small, undermines the very thing on which the continuity of our business and our ability to create jobs depends.  

It’s also illegal. If you’re caught paying even a small bribe, it can mean big trouble for us – and for you. 

So please be crystal clear: no matter where you are working, no matter what the hassle, we would rather put up with delays or lose business, than pay the real price of a facilitation payment. 

And anyone who tells you to ignore that, or that we don’t mean it, has no place working for us.  

It doesn’t matter how small the sum involved, we don’t make facilitation payments.

It seems to be legal

I’m working in a “high risk” country, and need some paperwork done fast. 

So I meet up with the officials at their office, tell them how urgent this is, and ask them if there’s any legal way this matter can be sorted. 

I stress that I can only accept a legal solution. 

They say yes, there is a way they can help and get this done. 

They tell me what the cost is going to be. It’s a bit pricey, but honestly, it seems fair enough, given what I’m asking them to do. 

However, there’s no actual published tariff for the work, and they say that in a case like this, because it has to be done so fast, payment has to be in cash. 

What should I do? …

The roadblock

This is a corrupt country. Officials like the police – even the doctors – barely get paid. So most try to supplement their income by demanding bribes. Nothing big – just small payments. But it’s pretty much for everything. You can’t avoid it. 

There was this one day I had to visit a site. The only way to get there was by car – a five hour drive. I had a guide with me. 

About an hour out of the city we saw a roadblock up ahead. It was a make-shift pole across the road. There was a police car and two policemen. 

They flagged us down. My guide told me not to worry, all they wanted was ten, maybe twenty dollars and we’d be on our way. He got out to pay, but I stopped him and told him my company didn’t pay bribes.

He looked at me like I was born yesterday and asked if I wanted to get to my destination or not. I said, of course. ‘Then you have to pay,’ he said. ‘Everyone pays.’

I had to get to the site that day, but if I didn’t pay it was clear they weren’t going to let me through.

I just didn’t know what was the right thing to do … 

Easy does it

A “Facilitation Payment”.  After the guy came, Jorge explained what it was. He told us it comes from the French word, facile, which means “easy”. A payment to make things easy. 

That’s what this guy offered all five of us. Nothing secretive – he came right out with it. 

We were round the front having our break, when suddenly he was there, waving an arm and calling out. He came over, asked us how we were doing. Then he told us we could help him. 

He showed us a photograph of one of his vehicles and said we’d be seeing a lot of them over the next few months. That was because he had a new contract, and had to make sure every delivery got there on time. Otherwise his customer would go elsewhere. He employed over a hundred people – and they’d all lose their jobs if that happened. 

He said if we could help him - make it easy for him - he’d be very grateful. And he pulled out this great wad of cash, said it was for us to share, as a team – and there’d be the same every month. 

Everyone else on the team has agreed we should just take the money – a little bonus each month. But I’m not so sure … 

Maintaining the status quo 

I’ve only just found out – and it’s a real problem. 

The project had been running for three years before we arrived to take over, and was one of our real success stories. It was surprising – it’s not easy to set up a new business in this part of the world. But our predecessors had clearly overcome the difficulties. 

We spent the first couple of weeks getting to know the ropes, going through the books and meeting the key people in the business – good relationships are if anything even more important here than elsewhere. 

Everything was in order – a really well-run operation. 

And then this bombshell.  

It seems that our predecessors had made arrangements with a number of different officials, and were making regular “off the books” payments to them. It wasn’t a lot – everything was paid from petty cash and put down as “expenses”. 

But of course now it’s what those officials are going to expect. 

Should we really tell them everything’s changed and there’s going to be no more money? 

And how do we do that without creating all sorts of serious problems for ourselves?

I just don’t know what to do …

Everyone does it 

I’m new – I’ve still got a lot to learn. But what I’ve seen just doesn’t seem right.

Everyone does a hard job here. The people we look after are generally regarded as “trouble” – although you could say they’re troubled.

Anyway, even though things can be tough sometimes, it’s an important and responsible job. 

But this morning I saw one of our officers taking something from a visitor. I couldn’t swear, but it looked like cash. 

There’s a real problem with drugs here – and I just didn’t like what I saw. 

So I happened to mention it to one of the guys. ‘Just keep your eyes down,’ he said. ‘and in a few weeks’ time you’ll be getting your perks too.’ 

“’Perks?’” I asked him. ‘What do you mean?’ 

“Come on!,” he said. ‘You really think anyone would do this for the pay they give us? Course there are perks. Everyone does it.” 

Like I say, I’m new, I’ve still got a lot to learn. But I don’t think that’s right. Only what am I supposed to do? Report all my colleagues? 

Maybe I should just accept that this is how things work round here … 

They’re threatening me  

I’ve been in this room for three hours now.  It’s dark – just the light coming from under the locked door. 

I can hear them arguing. One of them seems really agitated. 

And they’ve still got my passport.

I told them I wasn’t going to pay. Even after they showed me some old faded poster they claimed proved the fee they were asking was official. It was so obviously a fake. 

I told them I’d checked, and there was no fee to be paid. Then one of them started shouting at me so I shouted back. ‘As soon as I get out, I’m going to report this, and you!’

That’s when they put me in here. A while back the younger one came in and pleaded with me to just pay. Then they’d let me go. 

I told him, no – Serco will not pay illegal fees.  I even quoted our Code to him: ‘No matter what “local custom” may be, all forms of bribery and corruption, and even the smallest facilitation payment,
are forbidden.’ 
 
But I don’t know, I’m a bit scared now. Maybe I should just pay …

A simple business arrangement.

He had such a nice smile.

I was working in the front office when he came in. Said he was from the Government, paying a friendly call. 

‘And how long have you worked in my country?’ He looked at me like he really wanted to know. So I told him we’d started just a couple of months ago, and how much we liked his country – such friendly people.

‘Yes!’  he said, ‘But it must be so strange for you, trying to get used to our ways here. And so much bureaucracy.  I noticed that you had applied for a permit. In writing. Now you’ll have to wait for that to go through all those different departments. It’s like a minefield – and so inefficient.’ 

I began to realise that behind the friendly smile was an agenda – and I was about to find out what it was. 

‘We like to encourage business,’ he said. ‘That’s why we like to help companies like yours avoid all that muddle. So you don’t encounter any obstacles in the future. Obstacles that can hold business up for weeks – even months.’ 

‘We do it all the time, especially for clients like you. And that way you can be sure that none of those obstacles will get in your way. You don’t want that to happen – believe me.’ 

He looked at me, and that smile – it was like the grin of a hyena.

‘It’s a very simple service - very efficient. You pay a small fee every month. No effort for you – I come to collect it. And my position as a government official allows me to keep the path clear for you. Otherwise – well that’s not something you want to think about.’ 

He put a card on the desk. It said, “Government Facilitation Services”, and there was a name and a contact number. ‘Perhaps you can let me know what you’d like to do,’ he said. 

And with that smile he was gone. 

I sat there a long time. The threat was so clear – pay a small sum, and we’d be fine. Don’t pay, and someone was going to make it really difficult for us. 

In my place, what would you have done? 

We are honest people – and we want everyone to trust us for that. We know that even the suspicion of corruption can destroy that trust and do terrible damage.

So we never take part in any form of corruption or bribery (including facilitation payments) no matter how small the payment – and we don’t get others to do it for us.

If someone offers or asks us for a bribe, or even if we just hear about it or are worried it might be taking place, we always report it.

It’s easy to see why organisations and individuals resort to bribery and corruption. 

For business, the potential benefits of bribery, particularly where it is the expected norm, include easier and swifter access into markets, and helping to win lucrative contracts. 

For individuals, they include financial gain, promotion – or just making a problem go away. 

But the potential and actual damage done, even when just small bribes are involved, is immense. 

“A great company – destroyed by a scandal” 

Acts of bribery and corruption are, by their nature, secretive. But in the end, and almost always, there’s no hiding place. 

History is littered with organisations that have been found out and seriously harmed or even brought down as a result. While the individuals involved will usually lose their jobs, and even end up serving a prison sentence.

When an organisation fails like this, it will lose the faith and trust of its stakeholders and of the market. And it will be punished with the imposition of fines and penalties and receive negative coverage from the media and angry consumers. 

That has catastrophic consequences for all those who work within it and rely on it. Real people are affected. Employees lose their jobs. Investors take a hit. Pensions suffer. So do partners and suppliers and consumers.

Even what might appear to be a “harmless little bribe” - like a $50 facilitation payment paid illegally to a government official to “speed things up” – can result in scandal, loss of reputation and trust, and those involved being punished, fired or imprisoned. 

When employees stop believing 

Even if the truth doesn’t get out into the world beyond, inside the company people talk, rumours spread – and that can and does have corrosive consequences. 

Employees want to believe in the organisation they work for. They want to know that the values they hold dear are values their company stands for. 

When their own company and culture lets them down, employees lose faith, and morale collapses. So does the trust, team-work and willing energy that allows a business to thrive. 

But all this is only a small part of the real fall out …

The harm done to societies and people 

We usually think of bribery and corruption as something that involves vast sums of money and large-scale illegal deals made behind closed doors. 

But where small scale bribery and corruption becomes endemic and is accepted as “the way things are” it can undo the whole fabric of a society – destroying jobs, trapping the poorest in poverty, preventing access to essential services. 

  • Want this job? Then pay us – and we’ll make it happen.  
  • Want to carry on running your shop? Then pay us – and we’ll make it easy.
  • Want your electricity to continue? Then pay us – or we’ll make it stop.
  • Want medicines for your sick child? Then pay us – or he’ll die.  

For countries where this has become the norm, corruption seeps into everything. Poor governance abounds. Investment disappears. Vital systems like education collapse. Criminal gangs control and ruin lives. Opportunities cease to exist.

We do not want to be a part of that. Which is why mycode says exactly that.

We stand for Trust, Care, Innovation and Pride. These describe what we value, what we want to do in the world – and how we want to do it. 

They are also about the trust and pride our people have in us, and the care and innovation they apply to their work. 

If we lose these things, we lose who we are. 

It doesn’t matter how small or harmless it may seem, or what “local custom” may be – we don’t ever give or accept any form of bribery or corruption (including facilitation payments).

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Gifts and hospitality

We always check before giving or receiving any gift or hospitality.

Conflicts of interest

We always declare any potential conflict of interest. If we’re not sure, we ask.

Working with communities

We support and respect the communities we work among.

Political activities and payments

We keep our relationships with government honest.

Competition and antitrust

We always compete fairly and openly.

Working with others

We deal fairly and honestly with suppliers, strategic partners and agents, and expect the same of them.

Trade sanctions and export controls

We take care to know and follow the rules.

Accurate records, reporting and accounting

We always maintain accurate records, reports and accounts.

Tax evasion

We never do it, or help anyone else to.

Money laundering

We will not take part in any money laundering activity, and do all we can to stop it.

Insider trading

Never use inside information for insider trading – it’s a serious crime.