Anti-Fraud, Bribery & Corruption

1. Policy Statement

1.1  It is our policy to conduct our charitable business in an honest and ethical manner. We therefore take a zero-tolerance approach to fraud, bribery and corruption and are committed to: (a) acting professionally, fairly and with integrity in all our dealings and relationships wherever we operate, and (b) implementing and enforcing effective systems to counter fraud, bribery and corruption.

1.2  We take the most serious view of any actual or attempted act of fraud, bribery or corruption and will uphold all laws relevant to countering fraud, bribery and corruption in all the jurisdictions in which we work, including, in the UK, the Fraud Act 2006 and the Bribery Act 2010, which apply to our conduct both in the UK and abroad, and, in the US, the Foreign Corrupt Practices Act 1977.

1.3  To ensure that Big Win Philanthropy continues to hold high standards of accountability, transparency and legal compliance, we have put in place clear guidance on our organisational framework for addressing the risks of fraud, bribery and corruption.

1.4  Our policy on anti-fraud, bribery and corruption applies to all persons working for or on behalf of Big Win Philanthropy in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners, sponsors, or any other person associated with us, wherever located.

1.5  Any employee who breaches our policy will face disciplinary action, which could result in dismissal for gross misconduct. We will not conduct our charitable business with service providers, agents or representatives that do not support our anti-fraud, bribery and corruption objectives. We reserve the right to terminate our contractual arrangements with any third parties acting for or on our behalf with immediate effect where there is evidence that they have committed acts of fraud, bribery or corruption.

2. What is fraud, bribery and corruption?

2.1  Bribery is offering, promising, giving or accepting any financial or other advantage to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage.

2.2  Corruption is the abuse of entrusted power or position for private gain.

2.3  Fraud is where a person dishonestly makes a false representation, or dishonestly fails to disclose to another information which he or she is under a legal duty to disclose, or dishonestly abuses his or her position, with the intention to make a gain for him or herself or another, or to cause loss to another or to expose another to a risk of loss. Theft is also included in our policy.

2.4  All forms of fraud, bribery and corruption are strictly prohibited.

2.5  You must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible fraud, bribery or corruption.

3. Gifts and hospitality

3.1  As part of its anti-fraud, bribery and corruption measures, Big Win Philanthropy is committed to transparent, proportionate, reasonable and bona fide hospitality and promotional expenditure. Such expenditure must meet the criteria set out in our anti-fraud, bribery and corruption policy.

3.2  Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers), or be given in secret. Gifts must be given in Big Win Philanthropy’s name.

3.3  Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers and business partners.

4. How to raise a concern

4.1  If you suspect that a breach of this policy has occurred or may occur, you must contact our Chief Operating Officer as soon as possible.


Last updated August 2021.