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Anti-Bribery Policy

1. Policy Statement

Kidney Care for All CIC (KCA) is committed to conducting its business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our dealings, wherever we operate.

1A. Anti-Corruption Statement

KCA is also committed to preventing corruption in all its forms. Corruption, including the abuse of entrusted power for personal gain, undermines trust and integrity. This policy extends to any form of corrupt behaviour, whether or not it involves bribery. We expect all directors, staff, and associates to act honestly and ethically, and to report any suspicions of corruption promptly and in accordance with this policy. We uphold all laws relevant to countering bribery and corruption in the UK, particularly the Bribery Act 2010.

2. Who is covered by this policy

This policy applies to:
– All directors (including Chairman, Treasurer and Secretary)
– Any staff, volunteers, consultants or contractors working on behalf of KCA
– Any third parties or individuals associated with the company

3. What is bribery?

Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal, unethical or a breach of trust. A bribe can be in the form of cash or a gift, entertainment or hospitality, or anything else of value.

4. Our stance on bribery

KCA does not:

– Offer or accept bribes to gain or retain business or a business advantage

– Make facilitation payments (small unofficial payments made to secure or expedite a routine action)

– Make or accept improper donations or sponsorships

5. Gifts and Hospitality

Normal and appropriate hospitality (given or received) is acceptable provided it:

– It is not made with the intention of influencing a third party to obtain or retain business

– Complies with local laws

– Is given in the name of the organisation, not an individual

– Is appropriate in the circumstances and transparent

– Is of reasonable value and infrequent

All gifts or hospitality offered or received must be declared to the Treasurer and recorded in a register maintained by the Secretary.

6. Donations and Sponsorships

KCA only makes charitable donations that are legal and ethical and do not constitute disguised bribery. All donations must be approved by the Board of Directors.

7. Responsibilities

All directors and associated persons are responsible for:

– Reading, understanding, and complying with this policy

– Avoiding any activity that might lead to or suggest a breach of this policy

– Reporting any concerns or suspicions of bribery or corruption promptly

8. Reporting Concerns

Any concerns about suspected bribery should be reported to the Secretary or Treasurer in confidence. Reports will be treated seriously and investigated promptly.

9. Breaches of this policy

Breaches of this policy by directors or associated individuals will result in disciplinary action and may result in removal from office or termination of relationship with KCA. Where appropriate, the matter may be referred to the relevant authorities.

10. Review and Oversight

This policy will be reviewed annually by the Board of Directors to ensure its effectiveness. All directors will be reminded of this policy at least once annually.