Bribery and corruption toolbox

Toolbox

Our policies, procedures and other resources

Group policies are available on our website and can be viewed here.

These policies and supporting procedures form the Serco Management System (SMS). The SMS sets out for each policy area requirements by role so you can understand what is expected of you. It also provides supporting procedures and related documents.

Access to these documents is for Serco colleagues only and you will need to log into myserco to access them. If you have problems accessing them, please request a copy from your manager.

You can access the following here:

Group Policy Statement
- Business Conduct & Ethics
Function manual
- Third Party Due Diligence
Procedure
- Incident Reporting
- Charitable Donations, Sponsorships and other Contributions
- Gifts and Hospitality
- Political Donations and Activity
- Raising a Concern
- Speak Up (Handling Issues)
Guidance
- ABC Risk Indicator Questionnaire
- Customer Due Diligence Questionnaire
- Due Diligence Mergers & Acquisitions
- Entering Donations Sponsorship and Political Activity information on Assure
- Handling facilitation payments
- New country due diligence

You may also wish to view:

Anti-Bribery and Corruption Supplement

Definitions

When you offer someone money or a gift or a favour so you can influence them to do something for you that they shouldn’t, or so you can get an unfair advantage, that’s a bribe and it’s corrupt. So is asking for a bribe, and so is receiving one.

One common form of bribery is a ‘kick back’ – you agree to do something you shouldn’t, and when you’ve done it you get an unearned reward.

There are lots of everyday words and slang terms that tell you what bribes are about. For example: back-hander, hush money, palm-greasing, buy-off, bung, carrot, sweetener.

Corruption is any improper behaviour that tries to gain an advantage by doing something that is not legitimate or legal.

Other meanings of the word tell you what corruption really does: causing rot and decay; infection; undermining moral integrity; using a position of trust for dishonest gain; destroying someone’s honesty or loyalty.

Corruption undermines the law and the integrity of a system, and those who are corrupted usually put themselves in the power of those who corrupt them. That’s why criminals use it.

Bribery, abuse of power, extortion, fraud, deception, collusion, cartels, embezzlement, and money laundering are all forms of corruption.

These are illegitimate sums of money – often very small sums – but can also be small gifts or favours that an official may ask you to pay to speed up or “facilitate” a process they’re in charge of or have influence over. In fact, the official is threatening that unless you pay a bribe, they may obstruct or hold up a process that should be carried out in good time.

That’s why they are sometimes referred to as “grease” or “speed” payments.

Even if someone tells you that it’s local custom to pay, and the sum is small and will save a lot of potential hassle, this is bribery, which we have a zero tolerance for. So it doesn’t matter how small the sum involved, we don’t make facilitation payments.

If you're a manager

Make sure everyone understands Serco’s zero tolerance to any form of corrupt behaviour, either directly or indirectly, anywhere in the world.
Never accept, offer or approve any irregular payment or payment in kind to win business, encourage others to act improperly or influence a decision in our favour.
Do not make or approve facilitation payments and do not allow others who work for us or represent us to make them.
Ensure any allegation of potential bribery or a facilitation payment is fully investigated, reported to the divisional Ethics and Compliance Lead and recorded on Ethicspoint (through Speak Up).
Be vigilant to ensure our policy on corruption, bribery and facilitation payments is followed by our business partners, including joint ventures, agents, contractors and suppliers.