Volunteer - Anti-Bribery and Corruption

Policy

The Institution of Engineering and Technology

Futures Place
Kings Way
Stevenage
SG1 2UA

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Volunteer – Anti-Bribery and Corruption Policy

1. Why we have this Policy

1.1. The IET runs its activities with integrity. All of us must work together to ensure that they
remain untainted by bribery or corruption, or allegations of it. This Policy is integral to
that effort. Our staff colleagues are bound by a similar policy.

1.2. The IET (including all of its subsidiaries, wherever located) is subject to the UK’s Bribery
Act 2010 (the Act).

2. Who this Policy relates to

2.1. This Policy applies to all IET volunteers.

3. Other Policies, Procedures and/or Guidelines you need to read in relation to

this Policy

3.1. You should also read the following IET policies available in the IET EngX
Volunteering community

3.1.1. Gifts and Hospitality Policy for volunteers

3.1.2. Conflicts of Interest Policy for volunteers
3.1.3. Expenses, Subsistence and Travel Policy for volunteers
3.1.4. Anti-Slavery Policy
3.1.5. Whistleblowing Policy for volunteers, and:

3.1.6. Whistleblowing Guidance for members on the IET website

4. What is bribery?

4.1. A bribe is:

4.1.1. an inducement or reward offered, promised or provided;

4.1.2. in order to gain any commercial, contractual, regulatory or personal advantage;

4.1.3. through the improper performance of a business or employment-related function or

activity.

4.2. Performance will be improper if it is not in good faith, is not impartial, or if it is in

breach of an expectation of trust.

4.3. In practical terms, the inducement or reward offered could take a variety of forms. It
may take the form of cash or cash equivalent, gifts, meals, entertainment, services,
loans, preferential treatment, discounts, or anything else of value.

4.4. Under the Act, it is illegal:

4.4.1. to pay or offer to pay a bribe;

4.4.2. to receive or offer to receive a bribe;

4.4.3. to bribe a foreign public official; and

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4.4.4. for a commercial organisation (which includes the IET and its national and
international subsidiaries), to fail to have adequate procedures in place to prevent
bribery.

4.5. The timing of the bribe is irrelevant, and payments made after the relevant event will
still be caught, as will bribes that are given or received unknowingly.

4.6. The IET’s position is simple: we conduct our activities to the highest legal and ethical
standards. We will not be party to bribery or corruption in any form. The IET takes a
zero-tolerance approach to bribery corruption by our people and our third party
representatives.

4.7. Bribery may be more tolerated in some business sectors or countries, and may be
called something else (for example, “facilitation payments” or “grease payments”).
You may be told such payments are normal practice and the IET will be
disadvantaged if it does not pay. This does not matter: all such payments are illegal
under the Act.

4.8. If you are unsure about whether a particular act constitutes bribery, raise it with your
IET staff contact.

4.9. Specifically, you must not:

4.9.1. give or offer any payment, gift, hospitality or other benefit in the hope or expectation
that a business advantage will be received in return, or to reward any business
advantage received;

4.9.2. accept any offer of any payment, gift, hospitality or other benefit from a third party that
you know or suspect is made with the expectation that it will result in a business
advantage for them or anyone else;

4.9.3. give or offer any payment to a government official, agent or representative in any
country to “facilitate” or speed up a routine or necessary procedure;

4.9.4. threaten or retaliate against another person who has refused to offer or accept a bribe
or who has raised concerns about possible bribery or corruption;

4.9.5. take un-receipted, unauthorised or illegitimate payments directly or indirectly on

behalf of the IET, even if it is common practice to do so.

5. Gifts and hospitality

5.1. This Policy does not prohibit the giving or accepting of reasonable and appropriate
hospitality for legitimate purposes such as building relationships, maintaining our
image or reputation, or marketing our products and services. Our Gifts and Hospitality
Policy – Volunteers sets out the parameters for such hospitality, and the procedure
for declaring and or obtaining approval for gifts and hospitality where necessary.

6. Reporting

6.1. Each of us has a responsibility to speak out if we discover anything corrupt or

otherwise improper occurring in relation to our business. We cannot maintain our
integrity unless we do that. If you discover or suspect corruption in any form, whether:

6.1.1. by any staff member or volunteer;

6.1.2. by a third party who represents us;

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6.1.3. by one of our suppliers or competitors; or

6.1.4. by anyone else, such as a government official or even a customer trying to get better
terms, please report it to your IET staff contact and the Legal and Compliance
Department legalandcontracts@theiet.org as soon as possible.

7. What happens if you do not follow this Policy

7.1. Involvement in bribery and corruption carries many risks. Among them are:

7.2. an organisation which pays or accepts bribes is not in control of its affairs;

7.3. even an allegation of bribery, let alone an exposure of it, would entail severe
reputational damage. The government departments and institutions and companies
we work with may well refuse to work with us, and we could not tender for public
sector contracts and many private sector contracts;

7.4. any person guilty of bribery will be subject to fines and/or imprisonment (up to 10
years under the Act);

7.5. if the IET is found of guilty of bribery – or even of failing to have adequate procedures
in place to prevent it – it will be subject to large fines;

7.6. the cost of our insurance cover could increase very significantly; and

7.7. good people will not want to work for us.

7.8. If you give or take a bribe while volunteering for the IET, you may be subject to
disciplinary action under the IET Rules of Conduct (if you are a member) and/or the
IET Volunteer Code of Conduct.

8. Queries and Comments

8.1. If you have any queries regarding how this Policy works in practice, or comments or
suggestions as to how it could be improved, please contact the Volunteer Support
Unit on volunteer@theiet.org

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Appendix A
Control Sheet

Volunteer – Anti-Bribery and Corruption Policy

Document owner: Volunteer Support Unit
Document reviewer: General Counsel
Document adopted on: 1 April 2014
Next review date: 1 June 2024

Review/change history

Date of
Summary of changes Version no.
Review/Change
January 2014 First version 1.0

References to ‘staff and contractor’ which are in

complementary policy have been removed. Reference
July 2015 to Whistleblowing Policy (staff policy) removed. 2.0
Reference to on-line training removed and will be
replaced when available to volunteers.
Reformatted into new layout for Policies. References to
January 2016 new Gifts & Hospitality Policy – Volunteers, Conflicts of 3.0
Interest Policy – Volunteers and Whistleblowing Guidance
inserted.
January 2018 Reviewed – no changes. 3.0

June 2023 Reviewed. Updated to reflect up to date anti-bribery and 4.0

corruption legislation and best practice. Added references
to reporting and to additional relevant volunteer policies.

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