ISSE ANTI‑BRIBERY AND ANTI-CORRUPTION POLICY

Purpose and Scope

This policy applies to all directors, officers, employees, members, volunteers, contractors, consultants and any person acting in any way on behalf of the ISSE.

Its aims are to:

    • Establish a zero‑tolerance approach to bribery and corruption.
    • Ensure compliance with relevant legislation, such as the UK Bribery Act 2010.
    • Protect the reputation of the ISSE and maintain the trust of members and partners.
    • Provide clear guidance on acceptable conduct and reporting procedures.

Policy Statement

    • Zero tolerance and legal consequences – The ISSE strictly prohibits bribery, facilitation payments and kickbacks. Under UK law, bribery is punishable by imprisonment (up to seven years for individuals) and unlimited fines for companies. Breaches can result in exclusion from public contracts and severe reputational damage. Any ISSE representative found to have engaged in bribery will face disciplinary action and may be reported to the appropriate authorities.
    • Compliance – All personnel must comply with anti‑bribery and anti‑corruption laws. Books and records must accurately reflect transactions and there must be no off‑book accounts or “slush funds”.
    • Gifts and hospitality – Modest hospitality and ceremonial gifts may be acceptable if customary, proportionate and properly recorded. A reporting threshold applies: any gift or hospitality with an estimated value exceeding £50 (or local equivalent) requires prior written approval from a line manager or ethics officer. Regardless of value, gifts must not create a perception of influence or conflict of interest.
    • Third parties and due diligence – The ISSE will conduct due diligence on agents, consultants and business partners to ensure they meet ethical standards. Contracts will include clauses prohibiting corrupt practices.
    • Reporting and whistle‑blowing – All staff and members have a legal duty of care to report suspicious behaviour or concerns regarding bribery or corruption. Confidential channels are established; The ISSE subscribes to the Professional Institutes Joint Code of Professional Conduct which includes a dedicated Whistleblowing Facility and includes this within its Gold Standard Registration Scheme educational training programme.

Note: Any such submissions deemed to be:

    • Genuine – have NO REPERCUSSIONS upon the reporter(s).
    • Disingenuous – may be rejected and may be reported to the appropriate authorities.

NB: Any form of retaliation against whistle‑blowers is strictly prohibited.

    • Training and awareness – Anti‑bribery and anti-corruption training is included in the ISSE Gold Standard Registration Scheme educational training programme which incorporates a rigorous initial validation and periodical revalidation process.
    • Monitoring and review – This policy is reviewed annually. Compliance audits are undertaken periodically and findings reported to the Board.

Responsibilities

    • Board of Directors – Oversee compliance, approve the policy and ensure adequate resources.
    • Management Team – Implement procedures, carry out risk assessments and ensure effective controls.
    • All ISSE Personnel – are required to:
    • Complete the ISSE training programme in respect of all the ISSE policies
    • Adhere to the policy requirements including obtaining approval for gifts/hospitality over the threshold and reporting any associated concerns.

Customisation Guidance – All ISSE Personnel are required to adapt the gift‑approval threshold to reflect local currency, cultural norms and regulatory requirements. Where local laws impose stricter obligations, those requirements must take precedence. Smaller organisations without dedicated ethics officers may assign responsibility to a senior manager or trustee.