(8)  Conflict of interest

Personnel should be required to declare to relevant management any actual or potential conflict of interest, and should record this on a register which the organisation keeps for that purpose. 

A conflict of interest may include, for example, an ownership interest which the personnel or a member of the personnel’s family has in one of the organisation’s clients or suppliers.   

If any personnel do have a conflict of interest (e.g. with a client or supplier), the personnel should not normally be permitted to have any management involvement in decisions in relation to the organisation’s dealing with that client or supplier. 

Some conflicts of interest are too remote to have any actual impact.  For example, personnel may, through a pension fund, hold a relatively small number of shares in a publicly listed company with which the organisation does business.  This type of remote minority ownership is very unlikely in practice to lead to the personnel making any inappropriate arrangement with that other organisation, so would normally be exempt from the organisation’s conflict policies.

(9)  Benefits

Implement effective controls over the offering, giving or receipt of gifts, hospitality, entertainment, donations or other benefits (“benefits”).  In particular:

• prohibit any offering, giving or receipt of benefits which is, or could reasonably be perceived to be, for the purpose of bribery
• impose financial limits on any offering, giving or receipt of benefits, to ensure that they are not excessive, and are too minor to result in any actual improper influence
• require the offering, giving or receipt of benefits to be recorded in a register which is regularly inspected by the compliance function.

(10)  Training

Provide appropriate anti-bribery training and/or guidance to personnel on the ABMS.  The purpose of the training is to make relevant personnel aware of and understand:

• the anti-bribery policy
• the anti-bribery procedures which are relevant to their role
• the risks and damage to them and the organisation which can result from bribery
• the types of bribery they could encounter, and the circumstances in which it could occur
• any necessary preventive and investigative actions they need to take in relation to any bribery risk or suspected bribery
• how and to whom they should report any concerns.

This training should be provided to new personnel as soon as possible after they join the organisation, and then personnel should be provided with refresher training at reasonable intervals (e.g. annually).