Anti bribery policy

It is HOS policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and are committed to acting professionally, fairly and with integrity in all our relationships wherever we operate and to implementing and enforcing effective systems to counter bribery.

1. Overview

It is HOS policy to conduct all our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and are committed to acting professionally, fairly and with integrity in all our relationships wherever we operate and to implementing and enforcing effective systems to counter bribery.

We will uphold all laws relevant to countering bribery and corruption. We remain bound by the laws of the UK, including the Bribery Act 2010.

The purpose of this policy is to:

  • set out our responsibilities, and of those working for us, in observing and upholding our position on bribery; and
  • provide information and guidance to employees on how to deal with bribery issues.

In this policy, third party means any individual or organisation you encounter during your work for HOS.

2. What is bribery?

A bribe is an inducement or reward offered, promised, or provided to gain any commercial, contractual, regulatory, or personal advantage. The Bribery Act contains three types of bribery:

  • bribing another person
  • accepting a bribe
  • bribing a foreign official

3. Employee responsibilities

All employees are required to comply with HOS’s policies and procedures and apply best practice in order to prevent bribery. Staff should be made aware of their own responsibilities in protecting HOS from bribery.

Employees who are involved in or manage internal control systems will receive adequate training and support in order to carry out their responsibilities.

Employees are expected to act in accordance with the standards laid down by their professional institutes, where applicable, and have a personal responsibility to ensure that they are familiar with them.

All employees have a responsibility to comply with applicable laws and regulations relating to ethical business behaviour, procurement, personal expenses, conflicts of interest, confidentiality and the acceptance of gifts and hospitality. This means, in addition to maintaining the normal standards of personal honesty and integrity, all employees should always:

  • avoid acting in a way that might cause others to allege or suspect them of dishonesty;
  • behave in a way that would not give cause for others to doubt that HOS’s employees deal fairly and impartially with official matters; and
  • be alert to the possibility that others might be attempting to deceive.

All employees have a duty to ensure that public funds are safeguarded, whether or not they are involved with cash or payment systems, receipts or dealing with contractors or suppliers. If in doubt about a decision, employees are asked to ask themselves two questions:

  • What would the public expect? [of my decision, action, conduct, etc.]; and
  • How might the public perceive? [my decision, action, conduct, etc.]

Any employee who suspects that bribery has taken place should ensure it is reported to the Director of Finance & Corporate Services.

You must ensure that you read, understand and comply with this policy.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal.

4. Reporting fraud, bribery, or corruption

This section outlines the action to be taken if bribery is discovered or suspected. If an employee has any of the concerns mentioned in this document, they should, in the first instance immediately inform:

Michael Letters – Director of Finance & Corporate Services

Email –

You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage with the Director of Finance & Corporate Services, in accordance with HOS’s whistleblowing procedure. If you are unsure whether a particular act constitutes bribery, or if you have any other queries, these should be raised with the Director of Finance & Corporate Services.

If your concern involves the Director of Finance & Corporate Services, or the Chief Operating Officer, you should contact the Ombudsman. If your concern regards the Ombudsman, you should contact the Chair of the Audit and Risk Assurance Committee, Tim Leslie

5. What to do if you are a victim of bribery

It is important that you tell the Director of Finance & Corporate Services as soon as possible if you are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.

6. Protection

Employees who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.

HOS are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place or may take place in the future.

7. Hospitality and gifts

This policy does not prohibit some normal and appropriate hospitality (given and received) to or from third parties, provided that this is done in accordance with HOS’s Financial Procedures.

All employees must declare any gifts or hospitality that has been offered or accepted and it must be recorded on THO’s gifts and hospitality register which is saved in the e-Library. New entries to the register will be provided to each Audit and Risk Assurance Committee meeting.

8. Monitoring and auditing of policy effectiveness

Monitoring is essential to ensure that controls are appropriate and robust enough to prevent bribery. Arrangements include reviewing system controls on an on-going basis and identifying and responding to weaknesses in processes.

Where deficiencies are identified as a result of monitoring appropriate action plans are developed to implement any recommendations. These are monitored by the Senior Leadership Team.

This policy should be read in conjunction with the following policies:

  • Whistleblowing Policy
  • Disciplinary Policy
  • Standards of Business Conduct and Conflicts of Interest Policy