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Political activities and payments 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

  • Procedure

    • Organisational Conflict of Interest

    • Personal Conflict of Interest

    • Political Donations and Activity

  • Guidance 

    • Entering Donations Sponsorship and Political Activity information on Assure

    • How to review and approve a conflict of interest (People manager)

    • Managing personal conflicts of interest



An activity involving a Public Official but is NOT intended for general party support or for political campaigning that might involve the provision of resources including any property, services or facilities.

A lobbyist is an individual or an organisation who is employed to communicate with any public official to try to influence legislative or administrative action.

In some countries special laws and procedures govern the way lobbyists and consultants must behave. It’s important to know these and make sure we and anyone lobbying on our behalf always follow them.

This involves expenditures, cash or in kind, made directly or indirectly to a Public Official, political party or its branches, elected officials or political candidates or activities that involve political or public officials. This covers ‘Political Donations’, ‘Political sponsorship’ and ‘Activities involving political or public figures’.

It is a donation of money, goods or services made directly or indirectly to a Public Official, political party or its local branches that is given without charge or on non-commercial terms.  Expenditures can be for general party support or for political campaigning. Some examples of donations include: 

  • any gift of money, other resources or property (including free rent of facilities);

  • any sponsorship provided in relation to the party or Public Official to help them:

    • with any conference, meeting or other event

    • with any conference, meeting or other event

    • the preparation, production or distribution of any publication

  • any study or research;
  • any subscription or other fee paid for affiliation to, or membership of, a political party;

  • any money spent (otherwise than by or on behalf of the party) in paying any expenses incurred directly or indirectly by the party or Public Official;

  • the provision otherwise than on commercial terms of any property, services or facilities for the use or benefit of the party or Public Official (including the services of any person).

Also known as an industry trade group, business association, sector association or industry body) - is an organisation founded and funded by a group of companies and/or individuals with common interests or who work in the same industry. They act as a representative body for the industry they represent, putting forward the collective view and position of its members.  As the ‘industry voice’, trade associations sometimes speak on behalf of their members to government, agencies, regulators, the media and other opinion formers.

If you're a manager

  • Ensure due diligence is carried out and log any engagement with an elected politician, their adviser, or another government official who is covered by local lobbying laws and who is not a direct customer.

  • Ensure information provided to governments and regulatory bodies on behalf of Serco is accurate and complete.

  • Only attend an event hosted by a political party for briefing or other legitimate business purposes and ensure it will not compromise Serco’s impartiality.

  • Do not approve or make any political donations on behalf of Serco or use Serco money or resources to support political activities.

  • Make sure all exceptional Political Donations and activities are recorded in Assure.

Raise a concern

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What happens if we don't follow mycode?

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Bribery and corruption

We never take or offer any kind of bribe.

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.

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.