ANTI-BRIBERY AND CORRUPTION POLICY STATEMENT
Nigeria Network of NGOs is committed to applying the highest standards of ethical conduct and integrity in its
organisation activities. Every employee and individual acting on NNNGO’s behalf is responsible for conducting
organisation activities honestly and professionally.
NNNGO considers that bribery and corruption have a detrimental impact on the organisation by undermining good governance and distorting activities.
NNNGO benefits from carrying out its activities in a transparent and ethical way and by helping to ensure that there is honest, open and fair competition in our sectors. Where there is a level playing field, NNNGO can lead through innovation and by delivering excellent services to beneficiaries.
NNNGO does not tolerate any form of bribery by, or of, its employees or any persons or organisation acting for it or on its behalf. The Board and senior management are committed to implementing and enforcing effective systems to prevent, monitor and eliminate bribery, in accordance with the Corrupt Practices and other Related Offences Act 2000
NNNGO has issued an Anti-Bribery Policy. The Anti-Bribery policy applies to all employees and they are required to familiarise themselves and comply with the policy.
A bribe is a financial advantage or other reward that is offered to, given to, or received by an individual or organisation (whether directly or indirectly) to induce or influence that individual or organisation to perform public or corporate functions or duties improperly.
Employees and others acting for or on behalf of NNNGO are strictly prohibited from making, soliciting or receiving any bribes or unauthorised payments. As part of its anti-bribery measures, NNNGO is committed to engage only in transparent, proportionate, reasonable and bona fide hospitality and promotional expenditure.
A breach of NNNGO Anti-Bribery policy by an employee will be treated as grounds for disciplinary action, which may result in a finding of gross misconduct and immediate dismissal. Employees and other individuals acting for NNNGO should note that bribery is a criminal offence that may result in up to 10 years’ imprisonment and/or an unlimited fine for the individual and an unlimited fine for NNNGO.
NNNGO will not conduct its activities with service providers, agents or representatives that do not support NNNGO anti-bribery objectives.
The success of NNNGO anti-bribery measures depends on everyone playing their part in helping to detect and eradicate bribery. Therefore, all employees and others acting for, or on behalf of, NNNGO are encouraged to report any suspicious activity to the Compliance Officer. NNNGO Board will support any individuals who make such a report in good faith.
Message from the Executive Director
At NNNGO we are committed to doing the right thing, the right way. Our Code of Ethics and Behaviours outlines
the standards and behaviours that NNNGO upholds as an orgainsation, to ensure that the highest standards of
honesty and integrity are maintained. This is more important than ever because of the strict new rules
brought in by the Bribery Act.
We operate a zero-tolerance approach to the making or receiving of bribes or corrupt payments, in any form. This type of conduct is absolutely prohibited, whether committed by employees or anyone else acting on the organisation’s behalf.
This policy sets out what is and is not acceptable in general terms, but if you are in any doubt as to whether any conduct could amount to bribery, the matter should be referred to the organisation compliance officer, who is the Chief Compliance Officer for this policy. It is essential that you read and comply with this policy.
The Executive Director
Statement from the Chief Compliance Officer
As Chief Compliance Officer for NNNGO in respect of bribery and corruption matters I have overall responsibility for our compliance in this area. The Board considers bribery and corruption risks on a regular basis and is provided with ad hoc updates when necessary.
Chief Compliance Officer
- About this Policy
- Who must comply?
- How do you comply?
- What happens if you don’t comply?
- What you cannot do
- Checking out suppliers and partners: Due Diligence
- Gifts, Hospitality and Entertainment
- Political and Charitable Contributions
- Speaking up – Reporting Issues or Bribery
- If in Doubt/Advice
This policy sets out what we must all do to help prevent bribery in all its forms. A bribe may include any
payment, benefit or gift offered or given with the purpose of influencing a decision or outcome. The bribe
may not always be of a large value. It could be a lunch or an invitation to any event.
NNNGO is fully committed to complying with its obligations under applicable legislation, including the Bribery Act 2000 (the “Act”), and ensuring that no bribes or corrupt payments are made, offered, sought or obtained by anyone acting on its behalf, to anyone.
If you are ever in doubt about a situation with which you are presented, always seek advice. You should contact the Chief Compliance Officer on 0803 3483 421 or e-mail: firstname.lastname@example.org in the first instance.
The Nigeria Network of NGOs Anti-Bribery policy is mandatory for all NNNGO employees, agents, intermediaries,
consultants, distributors, sub-contractors, suppliers and Joint Venture partners working on the organisation’s
behalf anywhere in the world.
It is important that you take the time to read and comply with this Policy. The prevention, detection and reporting of any bribery in any form is the responsibility of all employees across NNNGO and all individuals and entities over which NNNGO has control. Appropriate confidential channels for employees and other Partners are in place to report any suspicion of bribery; these are described later in this Policy. Any failure to comply with this Policy will be treated seriously and may result in disciplinary action.
You must read and abide by the terms of this Policy. You may also be required to provide written
confirmation that you will comply with this policy.
Any act of bribery, in whatever form is unacceptable. We will consider taking disciplinary action against
anyone who fails to comply with the anti-bribery policy up to and including dismissal. Failure to comply with
this policy may also leave you open to a criminal prosecution under the Act. An offence under the Act can
result in a fine and/or up to a maximum of 10 years imprisonment.
For Nigeria Network of NGOs:
A breach of this Policy by an employee or partner could result in the organisation breaching the Act. An
offence under the Act can result in the organisation being fined and would likely lead to negative publicity
and serious damage to the reputation of NNNGO brand.
The following conduct is absolutely prohibited under this Policy:
- Making unofficial payments to officials in order to obtain any permission or permit;
- Appointing any third party or supplier to act on behalf of NNNGO who you know or have good reason to believe to have engaged in any corrupt or unlawful conduct including any offences under the Act; or
- Paying any third party for the purposes of being a ‘fixer’ to open doors.
- Appointing a new supplier;
- Entering into a partnership;
- Appointing an agent to work on the organisation’s behalf; or
- Entering into a new contract/or amending the terms of an existing contract
Facilitation payments (‘facilitating’, ‘speed’, ‘back-hander’ or ‘grease’ payments) are any payments, usually
small cash payments made to low-level officials, as a bribe to secure or expedite the performance of a routine
or necessary action or level of service.
NNNGO employees or Partners must never offer, pay, solicit or accept bribes in any form, including facilitation payments.
Exception: The only exception to paying a facilitation payment is where your life is in danger. If a facilitation payment is made in such circumstances, it must be reported as soon as practicable or possible to the Chief Compliance Officer, in order that it can be recorded.
NNNGO employees, and Partners should report, via the Employee Assistance Programme employee helpline any instance where a facilitation payment is alleged to have been paid on the organisation’s behalf.
Tel: 0802 8367 748
Where there is a Significant Bribery Risk all organisation units must consult the organisation Executive Director in relation to appropriate anti-bribery compliance measures before:
A Significant Bribery Risk will arise if:-
- The services being provided involve work being undertaken, directly or indirectly on our behalf, in any High Risk Jurisdiction;
- The services involve goods passing through borders between High Risk Jurisdictions;
- The services involve partners paying fees, taxes or payments on behalf of NNNGO in relation to the service(s)
- The services involves partners obtaining official permits, permissions or agreement from public officials or agencies; or
- There are any particular reasons to suspect that the risk of corruption or bribery is higher than normal.
- The contract with an agent or partner is signed or renewed;
- The agent does any work;
- The partnership undertakes any activities;
All NNNGO employees are expected to conduct themselves with integrity, impartiality and honesty at all times.
Accordingly, all employees are required to follow these rules on Gifts, Hospitality and Entertainment.
In addition, employees of NNNGO, irrespective of where they may be, are required to follow these standards.
We also expect employees of our partners to conduct themselves in accordance with these standards.
You must maintain a high standard of professionalism and not open yourself up to suspicion of dishonesty or put yourself in a position of conflict between your work and your private interests. Gifts and entertainment given and received as a reward, inducement or encouragement for preferential treatment or inappropriate or dishonest conduct are strictly prohibited. In particular, no gifts, hospitality or entertainment may be given or accepted during a tender process or during contractual negotiations if there is any realistic risk that such gifts or entertainment could influence the outcome of such processes or negotiations.
It is important that all NNNGO employees’ actions are able to withstand scrutiny, and not cause any embarrassment to the organisation, yourself or any third party, including contractors or partners.
Receiving and Giving Gifts
You may accept low value token gifts such as branded pens, stationery and mouse mats produced for the purpose
of being given away, if given by an existing partner or contractor. Occasional boxes of confectionary, etc,
may be given to a department as opposed to an individual. Otherwise you must refuse personal gifts such as
Christmas, wedding or birthday gifts, including vouchers or cash equivalents, received from partners,
suppliers, clients and other third parties.
Any gifts offered must be acceptable within the policy of the receiver’s organisation and if you are in any doubts about acceptability no gift should be provided.
NNNGO employees may occasionally receive invitations from contractor or others to corporate hospitality or
Hospitality or entertainment may only be accepted if:-
- Employees or personnel from the contractor are in attendance;
- The partners does not pay any accommodation or (more than trivial) travel expenses for NNNGO employees;
- The entertainment and/or acceptance of it could not be interpreted as a reward, inducement or encouragement for a favour or preferential treatment; and
- It is not unduly lavish or extravagant.
Hospitality and Entertainment Register
To ensure openness and transparency, all hospitality and entertainment must be recorded in the relevant
Hospitality and Entertainment Register on a monthly basis. These registers will be reviewed by the
Compliance Officer quarterly and reported to the Board of Directors annually.
Pertemps does not make contributions or donations to political organisations or independent candidates, nor
does it incur any political expenditure.
We respect the right of individual employees to make personal contributions, provided they are not made in any way to obtain advantage in a business transaction.
Pertemps communicates views to government and others, on matters which affect its business interests or those of its shareholders and employees, as a way of assisting in the development of regulation and legislation affecting the business.
NNNGO aims to conduct its activities with the highest standards of ethics, honesty and integrity, and
recognises that you have an important role to play in maintaining this aim. Any employee concerned about
any form of malpractice, improper action, or wrongdoing by the organisation, its employees or other
stakeholders are strongly encouraged to report the matter through the dedicated organisation staff helpline.
We believe it is essential to create an environment in which you feel able to raise any matters of genuine concern internally without fear of disciplinary action being taken against you, that you will be taken seriously, and that the matters will be investigated appropriately and as far as practicable be kept confidential.
NNNGO believes that any employee with knowledge of bribery in any form should not remain silent. We take all matters of malpractice, improper action or wrongdoing very seriously and you are strongly encouraged to raise incidents or behaviours that are not in accordance with the policy, by following the procedure set out below:-
In the first instance, you should consider raising your concerns with your supervisor. He has a responsibility
to listen and respond to any matter that is of concern to you. Concerns can be raised verbally or in writing.
Your supervisor will determine whether he is able to investigate the concern directly, keeping the Chief
Compliance Officer updated, if appropriate, of progress and its conclusion.
If your supervisor is unable to resolve the issue locally, he will escalate the concern to the Chief Compliance Officer, who will manage your concern in accordance with the Independent Internal Individual process set out below.
If you feel that you cannot raise your concern with your supervisor, for whatever reason, you should contact
the Chief Compliance Officer, who will consider the matter, manage any investigation, keeping the Executive
Director informed, if appropriate, of progress and its conclusion.
If the you are not satisfied with the way the issue is handled, you can escalate the concern to the Executive Director, who will manage your concern in accordance with the Independent Internal Individual process set out below.
If you wish to raise a concern using the confidential employee helpline as the nature of the concern is such
that you feel it cannot be raised internally, or if you feel that, after reporting the concern internally,
the matter still remains unresolved, you can raise the concern via the organisation’s confidential employee
helpline on 0802 8367 748.
The organisation recognises that there may be some cases where no wrongdoing is found through internal procedures. Protection will be given and no disciplinary action taken if the disclosure is reasonable, made in good faith and the information believed to be true.
The Board of Directors review arrangements, by which employees may, in confidence, raise concerns about
possible inappropriate activity. The Board reviews concerns raised through the Employee Assistance
Programme policy to make sure that any significant matters receive independent investigation and
appropriate follow up action. The Executive Director reports any information on allegations and
investigation results to the Board of Directors at least once a year.
If you have any questions you should contact the Chief Compliance Officer on 0803 3483 421 or e-mail:
Please ensure that you keep up to date with communications and updates on the intranet.