Anti-Bribery and Corruption Policy
1.0 Purple Frog’s Commitment
Purple Frog (Purple Frog Asset Management Limited) is committed to operating with the highest standards of integrity and promoting a culture in which accountability flourishes. Purple Frog opposes bribery as it erodes free and fair competition, damages good government and harms society at large. Purple Frog operates a zero tolerance policy towards the giving or receiving of bribes because it is morally wrong and it is illegal in the UK.
This policy outlines the measures which Purple Frog takes to prevent bribery and the procedures that should be followed if bribery occurs. It aims to help the organisation to establish a defence under section 7 of the Bribery Act – and to minimise any operational or reputational risks associated with individuals giving or taking bribes on its behalf.
This policy applies to all employees, volunteers, trustees, agents and service suppliers working with Purple Frog Asset Management Limited.
1.3 Relevant legislation
Bribery Act 2010
1.4 Related documents
- Finance policy
- Staff expenses policy
- Conflicts of interest policy
- Tendering policy
- Whistleblowing policy
- Disciplinary policy
2.1 Bribery: Bribery is the offering, promising, giving, accepting or soliciting of money, a gift or other advantage as an inducement to do something that is illegal or a breach of trust in the course of carrying out an organisation’s activities. Examples of bribery may include:
- A potential supplier offering you some money or a gift in order to influence a tendering process
- A job applicant offering to pay you to increase his/her chance of being offer employment
- Offering a gift (eg excessive hospitality) to a local government planner in return for approval of a development application
- Offering payment to a government official in order to speed up or complete a process they are otherwise required to perform such as border/immigration control.
It is illegal to give or receive a bribe under the Bribery Act and organisations are liable for bribes taken or given on their behalf where it does not have adequate procedures in place.
2.2 Facilitation payments: Facilitation payments are payments which induce officials to perform routine functions they are otherwise obligated to perform. Facilitation payments are bribes and there is no exemption for them under the Bribery Act. Facilitation payments do not include legally required administrative fees and legitimate fast-track services.
2.3 Gifts and hospitality: These can range from small gifts (such as diaries) to expensive hospitality (tickets for major events, holidays etc). Hospitality or promotional expenditure which is proportionate and reasonable to demonstrating goods or services or reflecting your good relations is unlikely to qualify as a bribe. However extravagant gifts and
hospitality may be used to disguise bribes that are intended to induce improper behaviour (eg to fix the outcome of a tendering process).
Purple Frog entrusts all individuals across the organisation to take a proactive role in improving the organisation’s anti-bribery policy and practice.
3.1 Directors: The Directors will provide leadership, resources and active support for the implementation of this policy. Theyare responsible for ensuring that this policy and any associated policies are fit for purpose and complied with.
3.2 Managing Director: The Managing Director is responsible for ensuring that these policies and procedures are implemented consistently and with clear lines of authority. The Managing Director and Board of Directors will actively and visibly lead the organisation’s anti-bribery policy and practice.
3.3 Human Resources: Human Resources is responsible for ensuring that the spirit of this policy is incorporated into all aspects of Purple Frog’s people management including recruitment, promotion, training, performance evaluation, remuneration and reward – and that these policies are continually improved in consultation with staff.
3.4 Finance: Finance is responsible for ensuring that the spirit of this policy is incorporated into all aspects of Purple Frog’s finance management including corporate accounting, gifts, staff expenses and donations – and that these policies are continually improved in consultation with staff.
3.5 Managers: Managers are responsible for holding their direct reports and project partners to account. They are responsible for ensuring that their projects are properly planned and that risks are assessed and managed in line with this policy.
3.6 Individuals: Individuals are responsible for not giving or receiving bribes and challenging instances where bribery may occur. They are also responsible for reporting all bribery that they are aware of via the procedures laid out in this policy.
4.0 Bribery prevention
4.1 Top level commitment: Purple Frog is committed to tackling bribery at the highest level. Purple Frog clearly articulates its zero tolerance policy on bribery externally on its website and internally on its intranet.
4.2 Risk assessment: Purple Frog risk assesses the organisation annually in consultation with staff and reviews the risks presented by bribery as part of this.
Purple Frog recognises that the threat of bribery varies across countries, areas of work, partners and transactions and that our organisation must respond proportionately to those risks. Therefore projects which involve working with partners or overseas are individually risk assessed, in addition to the annual organisational risk assessment.
4.3 Due diligence
4.3.1 Recruitment: Purple Frog recognises that good anti-bribery practice starts from the outset of employing an individual. It therefore: requires a commitment to preventing bribery in all person specifications for job vacancies includes a question to evidence the candidate’s commitment to preventing bribery in all job interviews ensures that all employment contracts prohibit the giving or receiving of bribes on behalf of Purple Frog
In addition, a thorough programme of staff communication and training is provided (see 4.4).
4.3.2 Working overseas: Staff managing projects or working overseas receive anti-bribery training before they begin assignments (see 4.4). Managers must assess and manage the risks associated with working in specific countries or sectors before assignments start (see 4.2).
4.3.3 Working with service suppliers and in partnerships: Purple Frog is liable under the Bribery Act if a person “associated” with it bribes another intending to obtain or
retain business or a business advantage for Purple Frog. The act’s definition of an associate is deliberately broad to include individuals, incorporated and unincorporated bodies supplying services to Purple Frog (rather than just goods) or acting on Purple Frog’s behalf as a partner or agent. Purple Frog requires all individuals engaging suppliers of services and working with partners of behalf of Purple Frog to ensure that:
- Service suppliers and partners are selected through a transparent and competitive selection process. See Purple Frog’s Tendering Policy for more information
- Due diligence is carried out on partners and suppliers before entering into contracts (see 4.2)
- All partners and suppliers are briefed on Purple Frog’s anti-bribery policy and provided with a copy to brief their own staff
- Contractual agreements explicitly prohibit the giving or receiving of bribes on behalf of Purple Frog.
4.3.4 Charitable and political donations: A political contribution is a donation made to a politician, a political party or a political campaign. Purple Frog will not make political contributions. Purple Frog can make charitable donations so long as they can not be construed in any way as a bribe. Staff should ensure that any donation received or made by Purple Frog is not an incentive to conduct its business improperly. All donations must be approved in line with Purple Frog’s Conflict of Interests Policy.
4.4 Communication: All staff and suppliers must understand and comply with Purple Frog’s anti-bribery policy. To ensure that this is communicated, Purple Frog:
- Publishes this policy internally and on its external website
- Revises and publishes its code of conduct to explicitly forbid the giving or receiving of bribes and ensures that individuals sign up to this annually
- Briefs all staff on Purple Frog’s anti-bribery policy, as part of the organisation’s induction as a minimum
- Provides anti-bribery training to all trustees, the Managing Director, the Directors, individuals working overseas, individuals working with government bodies and individuals leading contracts
- ncorporates anti-bribery into the staff performance appraisal process.
5.1 What staff should do if they are offered or asked for a bribe
Individuals should reject demands for or offers of bribes and Purple Frog’s anti-bribery stance should be made
The only circumstance where payment might not necessarily be avoided is when health and security is seriously at risk. Managers should plan their operations and have security procedures to reduce the risk of payments being requested under duress.
5.2 Where bribery is suspected or where it occurs
To enable proper investigation, staff should record the details of any bribery or requested or attempted bribery, as soon as possible after the event. Any instances of actual or potential bribery should be properly and promptly investigated by a director under Purple Frog’s Whistleblowing Policy. The objectives of an investigation should be to:
- Confirm whether or not a bribe has taken place, and to identify who was responsible.
- Confirm whether internal controls and anti-bribery procedures have worked in practice.
- Identify any improvements required to anti-bribery procedures.
- Depending on the findings of the investigation, subsequent action will be determined. This may involve disciplinary action against staff involved or external reporting to:
- A senior official or director of another organisation, if the person making the bribe is from that organisation
- Local police/ law enforcement agencies (if deemed appropriate)
- Serious Fraud Office (in the UK has primary responsibility for the UK Bribery Act)
- Relevant government department where the bribe took place See Purple Frog’s Disciplinary and Whistleblowing Policies for further information.
6.0 Monitoring and review
This policy will be reviewed annually or after a significant change in operations or a significant incident,whichever is sooner in consultation with Purple Frog staff.
Reviewed: Sept 2023 PG