Anti Bribery Policy

Boxing Futures prohibits the offering, giving, solicitation or acceptance of a bribe of any kind to or from any person or organisation, by any employee, third party or agent acting on Boxing Futures’ behalf, in order to gain a contractual or commercial advantage for Boxing Futures or to gain any personal advantage, pecuniary or otherwise, for themselves or anyone connected with them.

All staff must avoid accepting gifts and hospitality that might reasonably be thought to influence their judgement:
• The principle of integrity requires that staff should not place themselves under an obligation that might influence, or be perceived to influence, the conduct of their duties. This means that the receipt of hospitality and gifts must be subject to clear and sweeping restrictions and that any that are accepted must be declared and recorded.
• Employees must not accept cash, or personal gifts with a significant monetary value, under any circumstances. Items of nominal value, such as free promotional pens, calendars and similar items may be accepted.
• Personal gifts may not be solicited under any circumstances.
• Gifts from service-users should be politely refused. In unusual circumstances where polite refusal is likely to cause upset or offence and where the value of the item is unlikely to be significant to the service-user giving the gift, staff should share the gift with their colleagues and always record it in the hospitality register. When a gift is declined, the refusal should be courteous but firm, and draw the attention of the person making the offer to the existence of this Code.
• Staff should never accept lavish hospitality, or any hospitality which could be interpreted as a way of exerting an improper influence over the way their duties are carried out. Nor should staff offer such hospitality to others on behalf of Boxing Futures. The timing of hospitality in relation to procurement or purchasing decisions which Boxing Futures may be taking is especially sensitive. Above all, hospitality must never be solicited.
• When staff must decline hospitality, the refusal should be courteous but firm, and draw the attention of the person making the offer to the existence of this Code. If necessary, staff should pay our share of any costs, and claim these from Boxing Futures as an expense claim in the ordinary way.
• Staff may accept modest working meals and light refreshments without making any declaration or obtaining written consent.
• Other hospitality may be accepted, with prior written consent, for instance where:
o There is a genuine need to impart information or represent Boxing Futures in the community.
o Where an event is clearly part of the life or culture of the community or where Boxing Futures should be seen to be represented.
o the hospitality concerns attendance at a relevant conference or course where it is clear the hospitality is corporate rather than personal.

All such hospitality received must be recorded in the organisation’s hospitality register as should hospitality given on behalf of Boxing Futures.

Where an outside organisation wishes to sponsor or is seeking to sponsor the activity of Boxing Futures, whether by invitation or negotiation, or voluntarily, the basic conventions concerning the acceptance of gifts or hospitality apply.

The policy is not intended to prohibit normal and appropriate business practice such as reasonable hospitality or small gifts of a trifling nature. All hospitality, entertainment, gifts, donations, facilitation payments and other business expenses must be in accordance with Boxing Futures’s policies and procedures. Where an employee is uncertain whether a potential act would constitute bribery or be contrary to Boxing Futures’ policy, they should refer the matter to their Manager before proceeding. In any event, all hospitality, gifts or other items given or received must be formally recorded according to Company procedures. Failure to follow such procedures will result in disciplinary action.

In considering the use of third party suppliers or service providers, decisions must be made based on objective business criteria and appropriate records must be maintained to demonstrate this. All business partners, suppliers, agents, representatives etc. must be appropriately vetted.

The prevention, detection and reporting of bribery is the responsibility of all employees. Where there is any suspicion or evidence of bribery or corruption, this must be reported in accordance with the procedure for ‘Disclosure of Public Interest Matters’. Such reporting can be made confidentially.

This policy was approved on 17th June 2024.

Review date: May 2025.