Anti-Bribery and Corruption Policy

1. Purpose

This Anti-Bribery and Corruption Policy ("Policy") outlines our commitment to conduct business ethically and in compliance with applicable laws. The purpose of this Policy is to prevent bribery and corruption in all forms in the conduct of our business.

It is our policy to conduct all our 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 business dealings and relationships (including but not limited to members of the NCIP, training providers accredited by the NCIP, and their learners/students, staff and other stakeholders) wherever we operate, implementing and enforcing effective systems to counter bribery.

We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. We remain bound by local and national laws.

This policy is applied to all parties and stakeholders involved in the Operation of the NCIP, including but not limited to directors, employees, volunteers,

contractors, agents, members of the NCIP at all levels, members of the public as well as training providers accredited by the NCIP and their employees, 

volunteers and other persons involved in their work, their learners and students.

2. Scope

This Policy applies to all employees, directors, contractors, consultants, and any third parties acting on behalf of NCIP at all locations. 

3. Definitions

• Bribery: Offering, giving, receiving, or soliciting something of value to influence a business decision.
• Corruption: Abuse of entrusted power for private gain.
• Facilitation Payment: A payment made to expedite a routine governmental action.

4. Prohibited Conduct

[Company Name] strictly prohibits:

• Offering, giving, receiving, or soliciting bribes or kickbacks.
• Making facilitation payments, regardless of local customs or practices.
• Providing gifts or hospitality that influence, or appear to influence, the objectivity of the recipient.

5. Permitted Gifts and Hospitality

Gifts and hospitality may be provided or received pursuant to the following guidelines:

• Must be of nominal value (e.g., under $[Amount]).
• Must be lawful, transparent, and not intended to influence decision-making.
• Should follow the company’s prior approval process.

6. Reporting Violations

Employees are encouraged to report any suspected violations of this Policy. Reports can be made to:

• Immediate supervisors
• HR department
• Anonymous hotline: [hotline number/email]

All reports will be treated confidentially, and retaliation against anyone reporting in good faith is strictly prohibited.

7. Training and Awareness

All employees will receive anti-bribery and corruption training at the beginning of their employment and on an annual basis thereafter to ensure understanding and compliance with this Policy.

8. Due Diligence

Before engaging with third parties, [Company Name] will perform due diligence to assess their integrity and adherence to anti-bribery and corruption standards.

9. Monitoring and Enforcement

Compliance with this Policy will be monitored regularly. Any violation may result in disciplinary action, up to and including termination of employment.

10. Policy Review

This Policy will be reviewed annually or in response to significant changes in laws or business practices to ensure its effectiveness.

11. Effective Date

This Policy is effective as of [Effective Date].

Approval:

[Name]     Ray   Freeman
[Title]        Director
[Date] January 2025