1. Town and Country Housing Group’s Commitment
1.1 As a Registered Provider and a charity, Town and Country Housing Group (“the Group”) is committed to eliminating corruption and bribery and achieving the highest standards of good governance in all its activities.
1.2 The Group wishes to carry out its business transparently, fairly and honestly. It therefore operates a zero tolerance policy towards bribery by its board and committee members, employees, contractors, agents and other associated persons. Incidences of bribery could lead to the Group’s reputation being damaged and also lead to deterioration in its relationship with its tenants, customers, business colleagues and other stakeholders.
1.3 A breach of the Group’s Anti-Bribery Policy by an employee will be treated as a disciplinary matter under his or her contract of employment and an appropriate sanction may be applied. An investigation into any allegation of such a breach made against an Employee will be conducted in accordance with the Group’s relevant policies for such investigations. This policy does not form part of any employee’s contract of employment and it may be amended at any time.1.4 A breach of the Anti-Bribery Policy by a board or committee member will be treated as a breach of his or her duties and obligations to the Group and his or her services agreement and code of conduct with the Group. An investigation into any allegation of such a breach made against a board or committee member will be conducted in accordance with the Group’s relevant policies for such investigations and an appropriate sanction may be applied in accordance with the Group’s Board and Committee Members’ Code of Conduct / the Group’s standing orders and the Group’s Rules or Articles of Association.
1.5 The Group is committed to avoiding working with other organisations or individuals who do not commit to doing business without bribery. If there is no commitment shown then the Group may consider not entering into business with those organisations/individuals.
1.6 Inappropriate conduct can lead to prosecutions being brought against the Group and can impact directly on the Group’s public reputation. The benefits to the Business by rejecting bribery will include reputational integrity and customer and business partner confidence in the Group.
1.7 The Group’s anti-bribery policy is also designed to mitigate identified risks as well as to prevent deliberate unethical conduct on the part of associated persons. The following is a list of procedures included to assist with the Group’s anti-bribery stance:
- The involvement of the organisation’s top-level management.
- Risk assessment procedures.
- Due diligence of existing or prospective associated persons.
- The provision of gifts, hospitality and promotional expenditure; charitable and political donations; or demands for facilitation payments.
- Direct and indirect employment, including recruitment, terms and conditions, disciplinary action and remuneration.
- Governance of business relationships with all other associated persons including pre and post contractual agreements.
- Financial and commercial controls such as adequate bookkeeping, auditing and approval of expenditure.
- Transparency of transactions and disclosure of information.
- Decision making, such as delegation of authority procedures, separation of functions and the avoidance of conflicts of interest.
- Enforcement, detailing discipline processes and sanctions for breaches of the organisation’s anti-bribery rules.
- The procedures for the confidential reporting of bribery including ‘whistleblowing’ procedures.
- The detail of the process by which the organisation plans to implement its bribery prevention procedures, for example, how its policy will be applied to individual projects and to different parts of the organisation.
- The communication of the Group’s policy and training in their application.
- The monitoring, review and evaluation of bribery prevention procedures.
2. The Group considers that the procedures it has put in place will help with the prevention of bribery being committed on its behalf. The principles set are intended to be flexible and outcome focused to allow for the different circumstances the Group may find itself operating in. The Group’s bribery prevention procedures are detailed to be proportionate to the risks it faces in the environment in which it operates and will help it mitigate those risks in its business activities.
For more information you should contact our Company Secretary, who is Town and Country Housing Group’s Anti-Bribery Compliance Officer.