2.1. Policy


All FUND RA Staff and third-party service providers are prohibited from:

- Offering or suggesting a Bribe, or authorising the offer or suggestion of a Bribe 

- Paying Bribes

- Soliciting or accepting a Bribe to influence a decision, to obtain unauthorised access to confidential information, or to commit or omit to do an act, whether or not the outcome would have been the same without the Bribe 

- Making facilitation payments 

- Using another party to conduct any of the above 

- Using vendors or suppliers that do not have high standards on bribery and corruption 

- Processing funds known to be, or reasonably suspected of being, the proceeds of bribery or corruption


FUND RA will carry out appropriate due diligence on its clients, agents, and suppliers to minimise the risk of being associated with acts of bribery or corruption. In addition, the bribery and corruption risks are monitored and managed effectively in order to maintain a strong control system. Advice can be obtained from business line management as the first line of defence, who can seek further guidance from Security & Intelligence Managament (SIM) and (local) Legal or (local) Compliance to the extent required. Infringements of this Policy may result in disciplinary action by FUND RA, including dismissal, and may involve criminal or regulatory proceedings for individuals and FUND RA. This Policy should be read in conjunction with FUND RA’s Regulation Gifts policy. As it has been widely acknowledged that corporate gifts and hospitality, whether lavish or not, can be used as a subterfuge for bribery and corruption, It is therefore important that compliance with this Policy includes adherence to the rules within FUND RA’s Regulation Gifts policy as well as following the spirit of FUND RA’s zero-tolerance approach to bribery and corruption.


2.2. Facilitation payments


Facilitation payments are typically small unofficial payments paid to speed up an administrative process or secure a routine government action by an official. Examples of Facilitation payments include but are not limited to: 


- Obtaining or expediting a permit, licence or other official document or approval 

- Securing police protection for a site against risk of theft or arson

- Facilitating the collection and/or delivery of mail 

- Securing safe or prompt entry or exit from a jurisdiction or with regard to border controls or crossing and 

- The provision of utilities to a site, such as connection of water, electricity, gas or telephone services


Facilitation payments should be contrasted with official, lawful, receipted payments (typically to an organisation rather than an individual) to expedite certain functions, e.g. where there is a choice of fast track services to obtain a passport. FUND RA’s policy strictly prohibits any kind of Facilitation payments made by employees, agents or third parties acting on its behalf. If the safety or loss of liberty of staff or third-party service provider is at risk, the payment should not be refused. In all circumstances any demand for Facilitation payments must be reported to the local compliance officer immediately.


2.3. Indicators


The following are examples of relationships and events that could lead to a higher risk of bribery and corruption.


Fee payments


Where an agent or intermediary is used to make introductions to officials of public or government bodies and agencies, steps must be taken to ensure that any fee paid by FUND RA is proportionate to the activity being performed and in accordance with local law. No such fee payments can be made without the express approval of business line management who may obtain advice from (local) Compliance or, if necessary, (local) Legal (as may be appropriate).


Charitable donations


When funds are donated in FUND RA’s name for charitable purposes, appropriate due diligence must be conducted to ensure that, where a public official or public body is associated with the charity, written agreement is obtained from line management. Any charitable donation must always be made directly to a recognised charitable organisation and not via another party or individual. In case of doubt refer to line management who may obtain advice from (local) Compliance or, if necessary, (local) Legal.




Special requirements exist concerning the Fund’s provision of Sponsorship activities and these are set out in the Sponsorship Policy.


Public officials


Appropriate due diligence must be conducted when public officials, their relatives or their close associates are invited to any entertainment provided by FUND RA, or when payments are made to them by or on behalf of FUND RA. In assessing the amount of due diligence required, reference should be made to the Country Financial Crime Risk rating matrix of the level of corruption in a particular country and to FUND RA’s Politically Exposed Person (PEP) screening process.


Political donations


No political contribution to a candidate for public office, an elected official, a political party or political action committee, can be made, on behalf of FUND RA without prior approval from a member of the Managing Board.


Offers of employment


Care must be taken when providing work experience or employment to people that are connected to, or are relatives of, senior public officials. Although it is not prohibited to employ such staff it is important to avoid any perception that any hiring is for an improper purpose. Where such a hiring is being considered, approval from business line management must be obtained.


2.4. Advice and reporting


Where a member of staff knows of an actual incident or breach of this Policy or any attempt to bribe or otherwise engage in corruption, he/she must report immediately, in accordance with the Reporting & Prevention of Security Incidents and Compliance Breaches policy or the Global Policy on Employee Whistleblowing. Where there is suspicion or knowledge that funds held by FUND RA are intended to be used for, or are the proceeds of bribery or corruption, the responsibility is on the individual immediately to notify business line management who should assist the individual in contacting SIM, (local) Compliance or (local) Legal.