Anti-Bribery Code

Policy

Locksley Archery and ArcheryGB have a zero-tolerance attitude to Bribery and will conduct all of its business in accordance with the Bribery Act 2010. All activities will be carried out in an honest and ethical manner and will apply to both employed and voluntary personnel when representing Locksley Archery &/or Archery GB.

The penalties for committing a crime under the Act are a maximum of 10 years’ imprisonment, along with an unlimited fine, and the potential for the confiscation of property under the Proceeds of Crime Act 2002, as well as the disqualification of directors under the Company Directors Disqualification Act 1986.

Locksley archery & Archery GB are committed to implementing effective systems and procedures and enforcing them to counter bribery.

SCOPE OF POLICY

This Policy applies to:

• All personnel whether full time, part time or temporary;

All Voluntary personnel who have a position of authority ;

Any consultants doing commissioned work for Locksley Archery or Archery GB;

Any contractors undertaking work for Locksley Archery or Archery GB; or

Any other person providing services to Locksley Archery or Archery GB

For the purposes of this document the term ‘colleagues’ will include the above.

What is a Bribe

A bribe is a financial inducement or other advantage offered or given:

To or from any person to persuade them to/or reward them for performing their duties improperly;

To or from any public official with the intention of influencing that or other official in performing their duties; or

To or from any person or entity with the intention of influencing that or other official in performing their duties.

To or from any person or entity with the intention of improperly or unfairly influencing the scoring of archery tournaments .

Gifts and Hospitality

This policy does not prohibit giving and receiving promotional gifts of low value to a maximum of £50 sterling and normal and appropriate hospitality. To ensure openness & transparency all hospitality & entertainment offered / received must be recorded in the hospitality & entertainment register maintained by the CEO.

We will not provide gifts or hospitality with the intention of persuading anyone to act improperly or to influence an official in the performance of his/her duties.

Facilitation payments and kickbacks

We do not make and will not accept facilitation payments or “kickbacks” of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine action by any official. Kickbacks are typically payments made in return for a business favour or advantage. All colleagues must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.

Donations

We do not make contributions of any kind to political parties. No charitable donations will be made for the purpose of gaining any commercial advantage.

Record Keeping

We will keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.

All expense claims relating to hospitality, gifts or expenses incurred to third parties must be submitted in accordance with our financial procedures manual and specifically record the reason for the expenditure.

All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, must be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off-book” to facilitate or conceal improper payments.

Raising Concerns

All colleagues will be encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. No person will suffer any detriment as a result of raising genuine concerns about bribery, even if they turn out to be mistaken.

Concerns should be reported to the Chief Executive of Locksley archery  in the first instance. Should the concern include the Chief Executive, then the matter should be reported to the Secretary of the Board.

Non-Compliance

Failure for colleagues to observe this policy may lead to disciplinary action in accordance with the appropriate disciplinary policy

Where an individual / organisation is not subject to disciplinary procedures within Locksley archery or Archery GB, we will seek legal advice and take appropriate action.

Monitoring

The effectiveness of this policy will be annually.

Internal control systems & procedures will be subject to audit.