1. Policy Statement
It is our policy to conduct all our activities 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 honesty and integrity in all our dealings and relationships wherever we operate, and (b) implementing and enforcing effective systems to counter fraud, bribery and corruption.
We take the most serious view of any actual or attempted act of fraud, bribery or corruption and will comply with 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, and the Foreign Extortion Prevention Act 2023.
2. Introduction
Big Win Philanthropy’s reputation is an enormously valuable asset and could be seriously damaged by allegations of fraud, bribery or corruption. We must all work to avoid or prevent situations that may compromise this.
If found guilty of fraud, bribery or other corruption-related offences, companies can face significant penalties. In the UK, this can include unlimited fines and, in the US, substantial financial fines, penalties and other sanctions.
Individuals may separately face substantial fines and/or imprisonment. In both the UK and the US, custodial sentences can be significant and, in some cases, up to or exceeding 10 years, depending on the offence. Individuals who are also directors or officers of a company may also face restrictions on their ability to act in such roles. In the UK, this includes disqualification from acting as a company director for up to 15 years. In the US, similar restrictions may include being barred from serving as a director or officer of a company.
We have identified the following are particular risks for our charity. As part of Big Win Philanthropy’s programmatic work, we:
(i) Partner with government bodies.
(ii) Provide grant funding to governments.
(iii) Procure the services of foreign third parties.
(iv) Transmit funds to grantees abroad.
(v) Operate in countries with perceived high levels of corruption.We also invest our endowment funds in order to sustain our charitable activities.
To address these risks, we:
(i) Develop, maintain and consistently apply effective risk-based controls to prevent fraud, bribery and corruption at all levels (such as periodic risk assessments, training, due diligence on third parties, financial controls and appropriate contractual safeguards).
(ii) Ensure that if fraud, bribery or corruption occurs, a prompt and thorough investigation takes place, and that reports are shared with stakeholders as appropriate.
(iii) Take appropriate disciplinary and legal action where justified (with appropriate internal and external escalation where required, including to regulators or law enforcement).
(iv) Review systems and procedures to prevent similar frauds or acts of bribery or corruption.
(v) Ensure fraud, bribery and corruption risks are taken into consideration in programme planning.
3. Purpose
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.
The purpose of this policy is to:
set out Big Win Philanthropy’s responsibilities;
set out the responsibilities of those working for and on behalf of Big Win Philanthropy in observing and upholding our position on fraud, bribery and corruption;
provide information and guidance to those working for and on behalf of Big Win Philanthropy on how to recognise and deal with fraud, bribery and corruption issues; and
set out a response plan as part of Big Win Philanthropy’s framework, providing practical steps to follow in the event of suspected or confirmed fraud, bribery or corruption.
4. Application
This policy applies to Big Win Philanthropy UK and Big Win Philanthropy US, and to all persons working for or on behalf of them 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. In this policy, ‘you’, ‘your’ refers to all such persons.
5. Roles and Responsibilities
The Big Win Philanthropy UK and US Boards of Directors (Trustees) are duty bound to safeguard the assets of the charity, including its financial resources and reputation, and must ensure that proper financial controls and procedures are in place to help prevent misuse or abuse of Big Win Philanthropy’s funds. They have overall responsibility and are ultimately accountable for ensuring that Big Win Philanthropy, including everyone who works for or partners with us, complies with the applicable legal obligations and the ethical commitments expressed in our policy statement. The Audit, Risk and Controls Committee has been delegated the responsibility to review the adequacy and effectiveness of Big Win Philanthropy’s internal financial controls (including anti-money laundering systems) and internal control and risk management systems; review our fraud detection procedures, systems and controls for the prevention of bribery and receive reports on non-compliance.
The Chief Operating Officer (COO) has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering fraud, bribery and corruption. The COO, supported by the Legal Officer, also facilitates and delivers staff training on the policy and oversees or ensures appropriate oversight of any investigations, ensuring that concerns are addressed promptly and thoroughly, and that appropriate reports are made to the Boards when necessary. The Finance Director is responsible for ensuring that organizational anti-fraud, Know Your Customer and Anti-Money Laundering policies are applied with respect to payments.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy, and complete any training identified by the COO and the Legal Officer.
All staff must comply with this policy in everything they do on behalf of Big Win Philanthropy. They are expected to act with integrity, avoid conflicts of interest, and promptly report any suspicions or evidence of fraud, bribery, or corruption through the designated reporting channels.
Partners and grantees must comply with anti-fraud, bribery, and corruption obligations set out in their agreements with Big Win Philanthropy, and this policy. They must notify Big Win Philanthropy immediately if they become aware of any wrongdoing and cooperate fully with any investigation or audit.
You are invited to comment on this policy and to suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Chief Operating Officer or Legal Officer.
6. Definitions
In this policy, third party means any individual or organisation you come into contact with during the course of your work for Big Win Philanthropy and includes actual and potential supporters, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials.
Per diem refers to a cash payment intended to subsidise or facilitate lodging, meals, and other daily expenses which has been calculated on a daily rate basis instead of an actual cost basis.
Public official is any person acting in an official capacity for or on behalf of a public body and therefore covers a wide variety of individuals, ranging from civil servants and politicians to customs officials, teachers, police officers and tax inspectors. For purposes of this policy, ‘public official’ also includes political party officials and any candidates for political office.
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.
An advantage includes money, gifts, loans, fees, hospitality, services, discounts, the award of a contract, or anything else of value.
A person acts improperly where they act illegally, unethically or contrary to an expectation of good faith or impartiality, or where they abuse a position of trust. The improper acts may be in relation to any business or professional activities, public functions, acts in the course of employment, or other activities by or on behalf of any organisation of any kind.
Corruption is the abuse of entrusted power or position for private gain.
Fraud is where a person dishonestly makes a false representation, or dishonestly fails to disclose to another information they are legally obliged to disclose, or dishonestly abuses their position, with the intention to make a gain for themselves or another, or to cause loss to another or to expose another to a risk of loss. Theft is also included under this policy and will be treated as a form of fraud for the purposes of this policy.
Examples:
Offering a bribe: Kerr offers a funder tickets to a major sporting event, but only if they agree to fund a project being led by Kerr’s employer.
This would be an offence as Kerr is making the offer to gain a commercial and contractual advantage. The employer may also be found to have committed an offence because the offer has been made to obtain an advantage for it. It may also be an offence for the potential partner to accept the offer.
Receiving a bribe: A supplier gives Karen’s nephew a job, but makes it clear that in return they expect Karen to use her influence in her organisation to ensure they continue to do business with the supplier.
It is an offence for a supplier to make such an offer. It would be an offence for Karen to accept the offer as she would be doing so to gain a personal advantage.
Bribing a foreign official: Emeka arranges for the organisation to pay an additional "facilitation" payment to a foreign official to speed up an administrative process, such as obtaining approval for a project by Emeka’s organisation.
The offence of bribing a foreign public official is committed as soon as the offer is made. This is because it is made to gain an advantage for the organisation’s operations. Emeka’s employer may also be found to have committed an offence.
Committing fraud: Ivanka makes claims for journeys which were not made; she makes payment for goods or services which were not delivered; she steals incoming cash or cheques.
Each of these examples would be an offence because Ivanka has dishonestly abused her position, with the intention to make a gain for herself or another or loss to the organisation.
7. What You Must Not Do
It is not acceptable for you (or someone on your behalf) to:
give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a personal advantage or an advantage to Big Win Philanthropy will be received, or to reward such an advantage already given;
give or accept a gift or hospitality during any negotiations or tender process, if this could be perceived as intended or likely to influence the outcome;
give, promise to give, or offer, a payment, gift or hospitality to a public official, agent or representative to "facilitate" or expedite, or secure any action or decision;
accept a payment, gift or hospitality from a third party that you know, suspect or ought reasonably to suspect is offered with the expectation that it will provide an advantage for them or anyone else in return;
accept hospitality from a third party that is unduly lavish or extravagant under the circumstances;
threaten or retaliate against another individual who has refused to commit a bribery offence or who has raised concerns under this policy;
pay per diems or make any other cash payment to public officials other than reimbursements for reasonable, documented, approved, out-of-pocket expenses incurred in the course of Big Win Philanthropy’s charitable and related operational activities; or
engage in any other activity that might lead to a breach of this policy.
8. The Local Context
You must at all times consider the local context in which you are working. It is important that you are sensitive to, and respectful of, local laws and policies. If certain conduct is acceptable under this policy but not acceptable under local laws and/or policies then you should not engage in such conduct. Conversely, where local customs, practices or expectations may permit or encourage conduct that would breach this policy, you must comply with this policy and must not engage in such conduct, even if it is considered normal or customary locally. Where there is any uncertainty regarding local legal requirements, you should seek guidance from the Chief Operating Officer or Legal Officer.
9. Facilitation Payments and Kickbacks
We do not make, and will not accept, facilitation payments or "kickbacks" of any kind.
Facilitation payments, also known as "back-handers" or "grease payments", are typically small, unofficial payments made to secure or expedite a routine or necessary action (for example by a public official). They are not common in the UK or US, but are common in some other jurisdictions.
Kickbacks are typically payments made in return for a business favour or advantage.
You must avoid any activity that might lead to a facilitation payment or kickback being made or accepted by us or on our behalf, or that might suggest that such a payment will be made or accepted. If you are asked to make a payment on Big Win Philanthropy’s behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment. If the payment you are being asked to make or accept is improper you must refuse the request and report it as soon as possible to the Chief Operating Officer or the Legal Officer in accordance with the Fraud, Bribery & Corruption Response Plan (see Annex 2). If you are unsure the request is a facilitation payment, kickback or other improper arrangement or have suspicions, concerns or queries you should raise these with the Chief Operating Officer or the Legal Officer. Please also see Annex 1 for a list of ‘red flags’ to look out for in relation to these kinds of arrangements.
10. Gifts, Hospitality and Expenses
This policy allows reasonable and appropriate hospitality or entertainment given to or received from third parties, for the purposes of:
establishing or maintaining good business relationships; or
presenting our charitable activities effectively.
The giving and accepting of gifts is allowed if the following requirements are met:
it is not made with the intention of influencing a third party’s decision, action, or outcome, or as a reward for such influence, or in explicit or implicit exchange for favours or benefits, including in relation to funding, partnerships, procurement or other activities carried out by or on behalf of Big Win Philanthropy;
it is given in Big Win Philanthropy’s name, not in your personal name;
it does not include cash or a cash equivalent (such as gift certificates or vouchers);
taking into account the reason for the gift, it is of an appropriate type and value, and given at an appropriate time. For example, in the UK and US, it is customary for small gifts to be given at Christmas;
it is given openly, not secretly; and
it complies with any applicable local law.
Gifts and hospitality of low value (typically up to £30 / $40 per occasion per person) do not require prior approval but must be recorded in Big Win Philanthropy’s Gifts and Hospitality Register, which can be found in Box (see All Files > Admin-All Staff > Gifts). Gifts or hospitality above this threshold, or any involving a public official, must be approved in advance in writing by the President, Chief Executive Officer, or Chief Operating Officer or his designee. The cumulative value of gifts or hospitality received from or provided to the same individual or organisation / body over a rolling 12-month period must also be considered when assessing whether approval is required, and may require escalation to the Chief Operating Officer even if individual items fall below the threshold.
Promotional gifts of low value such as branded stationery to or from existing customers, suppliers and business partners will usually be acceptable and are subject to the threshold and recording requirements in paragraph 10.3 above.
It is common in some countries where Big Win Philanthropy works for guests to be given ceremonial “gifts” of nominal monetary value, such as scarves, food, and the like. De minimis gifts received in this context do not need to be recorded in the gift register if they are not kept by the recipient or have no reasonable resale value in the US or UK.
Reimbursing a third party's expenses, or accepting an offer to reimburse our expenses (for example, the costs of attending a business meeting) would not usually amount to bribery. However, a payment in excess of genuine and reasonable business / operational expenses (such as the cost of an extended hotel stay) is not acceptable. Please note, however, that Big Win Philanthropy does not permit the paying of per diems by Big Win Philanthropy to public officials.
11. Donations
We do not make contributions to political parties. We only make charitable donations that are legal and ethical under local laws and practices, and consistent with Big Win Philanthropy’s charitable status in the UK and the US, and their respective charitable objects. No donation must be offered or made without the prior approval of the President, Chief Executive Officer or Chief Operating Officer in writing.
12. Record-keeping
We must keep financial records and have appropriate internal controls in place which will evidence the charitable activities or related operational reason for making payments to third parties and ensure that such payments are properly authorised, recorded, and supported by appropriate documentation.
You must submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our Expenses Policy (saved on Box) and record the reason for expenditure.
All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept "off-book" to facilitate or conceal improper payments or any other improper financial arrangement.
You must also declare and record all hospitality or gifts offered to, or received by, you above nominal value (see paragraph 10.3 above) in Big Win Philanthropy’s Gifts and Hospitality Register, which will be subject to periodic review by the Finance and Legal teams.
Conflicts of interest are known to increase the risk of fraud, bribery and corruption. Therefore, you must declare any actual or potential interest, in writing, to the Chief Operating Officer or the Legal Officer. A conflict of interest will arise if you have a direct or indirect interest in a matter (whether personal, by virtue of a duty of loyalty to another organisation or otherwise) and that interest conflicts, or could conflict, with the interests of Big Win Philanthropy. A conflict of interest includes a conflict of loyalty; that is a conflict between any duty you owe to Big Win Philanthropy and any duty you owe to another person or organisation. See Big Win Philanthropy’s conflicts of interests policy (saved on Box) for more information.
Big Win Philanthropy staff must also comply with Big Win Philanthropy’s requirements for carrying out proper due diligence as set out in its policies and procedures.
13. Your Responsibilities and Raising Concerns
You must ensure that you read, understand and comply with this policy.
The prevention, detection and reporting of fraud, bribery and other forms of corruption are the responsibility of all those working for us or under our control. You must avoid any activity that might lead to, or suggest, a breach of this policy.
You are encouraged to raise concerns about any issue or suspicion of fraud, bribery or corruption at the earliest possible stage.
If you are offered a bribe, or are asked to make one, or if you believe or suspect that any fraud, bribery, corruption or other breach of this policy has occurred or may occur, you must notify the Chief Operating Officer or Legal Officer in accordance with the Fraud, Bribery and Corruption Response Plan (Annex 2). Further "red flags" that may indicate fraud, bribery or corruption are set out in Annex 1.
If you are unsure about whether a particular act constitutes fraud, bribery or corruption, you must also raise it with the Chief Operating Officer or Legal Officer as soon as possible and in accordance with Annex 2 (Fraud, Bribery and Corruption Response Plan).
14. Protection
Individuals who refuse to accept or offer a bribe or commit fraud, or 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.
Big Win Philanthropy is committed to ensuring that no one suffers any detrimental treatment as a result of refusing to take part in fraud, bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential fraud, bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Chief Operating Officer immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, details of which can be found in our Employee Handbook, and you may also raise your concerns under our Whistleblowing Policy where appropriate.
15. Training and Communication
Training on this policy forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.
Our zero-tolerance approach to fraud, bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter through contractual terms where appropriate.
16. Breaches of this Policy
Anyone who commits fraud, bribery or corruption or any other dishonesty, or who becomes aware of it and does not report it, will be subject to appropriate disciplinary action. Such disciplinary action could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
17. External Advice & Reporting
The Chief Operating Officer and Legal Officer should ensure that legal and/or police advice is sought where necessary, in accordance with Annex 2 (Fraud, Bribery and Corruption Response Plan).
Where actual or attempted fraud is committed in the UK, the Chief Operating Officer and Legal Officer should consider whether reports need to be made to Action Fraud, the Charity Commission for England in Wales (if it is a “serious incident” as defined in the regulatory guidance) and the Information Commissioner’s Office (if the incident relates to a data breach). Where actual or attempted bribery, fraud or corruption is committed in or with respect to the US, the Chief Operating Officer and Legal Officer should consider with to make disclosure to the appropriate federal and state authorities.
18. Contacts
Legal Officer: legal@bigwin.org
Last updated April 2026.
Annexes not included here can be requested from the Legal Officer at legal@bigwin.org.