Bribery and corruption toolbox

Toolbox

Our policies, standards and other resources

We have more in-depth Group policies and standards covering all aspects of bribery and corruption. You can find links to them here.

In addition, there may be specific policies and procedures that apply where you work. Your manager can tell you about these. If you are unsure then ask your manager.

(Please note: some of our resources are only available to Serco employees. In this case, you’ll need to log in to MySerco to access them. If you have problems accessing them, please request a copy from your manager.)

Business Conduct and Ethics
One page statement defining Serco’s commitment to operating with integrity.

Understand what is expected of you here.

Group Procedure – Gifts and Hospitality
Details the procedure for the recording and approval of all gifts and hospitality that are offered or received.

Group Procedure – Political Donations and Activity
Details procedures for reviewing, approving, and managing political donations and activities.

Group Procedure – Charitable Donations, Sponsorships and Other Contributions
Details procedures for reviewing, approving, and managing charitable donations, sponsorships, and related activities.

Group Procedure – Serco Essentials Training
Details the planning, development, deployment and review of mandated Serco essentials training.

Group Guidance – Handling Facilitation Payments
Defines Facilitation Payments, and why it is important to fight against them, it also sets out the process of what you should do to record a Facilitation Payment should it be made.

Group Functional Manual – Third Party Due Diligence
Covers the various processes for the completion of appropriate due diligence of various categories of third parties.

Group Procedure – Raising a Concern
Provides guidance on how to raise a concern.

Anti-Bribery and Corruption Supplement
Overview of our approach to ensure adequate procedures to address bribery and corruption.

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.