This section of the manual has been updated to strengthen our anti-corruption policy and provide practical guidance on managing the risk of bribery. This update coincides with the enablement of UK Bribery Act enabled on 1 July 2011.

(I) Declaration of Interests

In undertaking or participating in any aspect of procurement or commercial arrangement, staff are required to declare any personal interest which may affect or be seen by others to affect that member of staff's impartiality in a matter relevant to his or her duties. In the first instance this declaration must be made to the Head of Procurement and may be referred to the Director of Finance and or the Executive Management Team (EMT). Whilst the above policy places the onus on the individual to declare any personal interest, in certain circumstances staff may be required to sign a formal written confirmation of NO INTEREST prior to undertaking his or her duties. This requirement will be at the discretion of the Director of Finance and Head of Procurement.

or

Where an employee or a close relative of an employee acts as a supplier or, when the aforementioned hold significant interest in a business which trades or has potential for trading with RoS, then the employee is required to declare all such interests to the EMT. Declarations must be in writing and copied to the Director of Finance and the Head of Procurement. It should be noted that approval from the EMT is required before such 'interested' parties of the type identified begin to trade with RoS. 

(II) Inducements

It is an offence under the Prevention of Corruption Act 1906 for those employed by contracting authorities in their official capacity corruptly to accept any gift or consideration as an inducement or regard for doing, or refraining from doing, anything or showing favour or disfavour to any person.

Under the Prevention of Corruption Act 1916, any money, gift or consideration received from a person or organisation holding or seeking to obtain a contract will be deemed by the courts to have been received corruptly unless proved to the contrary.

No employee shall accept, directly or otherwise, any inducement in whatever form, from either current or potential suppliers, their agents, or any individual acting as their agent.

If, as a consequence of actions taken, a member of staff unwittingly or otherwise gains a significant personal advantage (e.g. vouchers, free travel, gifts) whether it be through a suppliers' promotional offer or any other source, then this advantage and the circumstances surrounding it must be declared as appropriate to their line manager, the Head of Business Unit or the Managing Director, and recorded in the Register held in the Human Resources Department. Promotional merchandise such as pens, mouse mats, calendars and diaries with a value under £25 are not classed as 'significant' and you may accept inexpensive, token or promotional gifts or benefits up to the individual or cumulative value of £25. You should use the appropriate HR form to apply for acceptance of any other gift or benefit. For further details of this policy see Section 2.3.9 of the Staff Handbook