1.1. Purpose


This Policy consolidates Fund for social and economic development of the regions "Treasury Creator RA" (hereafter referred to as FUND RA) stance on bribery and corruption, it complements FUND RA’s Core Values of integrity and the standards of behaviour expected from the fund’s staff worldwide. It gives effect to the latest regulations and legislation. FUND RA’s policy position is that any form of bribery and corruption is prohibited. This applies to accepting, offering, paying, giving, soliciting, or authorising bribes. This Policy sets FUND RA’s minimum standards. Where local laws are stricter than the standards contained herein, the local laws prevail. If, in exceptional cases, deviation from this Policy is requested, such deviation must be discussed with business line management who should liaise with Compliance to determine whether the request is acceptable and for the purposes of recording any such deviation together with the rationale for allowing any deviation. This Policy should be read in conjunction with the associated policies. In particular FUND RA’s Regulation Gifts policy, which set out the detailed policy requirements in relation to gifts and entertainment given to, or received from, clients and others.


1.2. Scope


This Policy applies to all activities and operations of FUND RA, irrespective of their jurisdiction, country or business. The Policy applies to:


- Members of FUND RA’s Managing Board

- Members of FUND RA’s Supervisory Board

- All FUND RA permanent staff 

- All FUND RA temporary staff (for example temporary workers, advisors and consultants). Together, FUND RA permanent staff and temporary staff are known as “staff” 

- The engagement of third-party service providers by FUND RA or any individual or corporate entity associated with FUND RA (for example suppliers, agents and sponsors).


This Policy applies to all public and private sector transactions in which FUND RA is engaged.


1.3. Background


The reputational and financial risks of the fund being involved in or becoming a vehicle for bribery and corruption are risks the fund takes seriously and wishes to mitigate. Corruption increases uncertainty in business and in the costs of transactions. It restricts international trade and reduces investment, and therefore growth, both within a region and globally. The international community has been aware of the negative effect corruption has on national economies and has enacted international agreements and domestic laws to help combat this. Bribery and corruption may among others be relevant for FUND RA in the following circumstances: 


- Staff or third-party service providers accept or solicit bribes 

- Staff or third-party service providers pay, offer or promise bribes 

- Staff or third-party service providers authorise the actions above 

- Clients misuse FUND RA’s services and/or facilities (including, without limitation, financial), for example to deposit or transfer the proceeds of bribes


Although corruption is regarded as an increased risk in relation to public officials, it is also relevant in the private sector context.


1.4. Definitions Bribery


This is the offering, suggesting, paying, or authorising of a payment to someone for their, or another’s personal gain with the intention either to motivate active or passive deviation from a duty or to secure the performance of a duty.




A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.




Refers to the state or situation resulting from providing, soliciting, authorising or offering a bribe.


Facilitation payments


See paragraph 2.2.This is defined widely and need not be monetary in nature; it can be of any value, and include goods, services and information.


Public official


This is any official or employee of a state or its agencies, including those who have been selected, appointed, or elected to perform activities or functions in the name of a state or in the service of a state. It also includes any official or agent of a public international organisation, private individuals carrying out official state functions, and officials of state owned enterprises. This is a wide definition and (local) Compliance or, if necessary, (local) Legal will be able to provide further guidance.