Bribery and Corruption Policy and Procedures:
Introduction
In line with the Bribery Act 2010 which came into force on 1 July 2011, NI-CO has reviewed
its policy in this regard. The board attaches the utmost importance to this policy and will
apply a “zero tolerance” approach to acts of bribery and corruption by any of our employees
or by business partners working on our behalf. Any breach of this policy will be regarded as
a serious matter by the Company and is likely to result in disciplinary action
The reputation of Northern Ireland Co-operation Overseas (NI-CO) Ltd is one of our greatest
assets and we will only be involved in lawful, ethical and honest business activities. The
Company recognises that any involvement in bribery will have an adverse effect and
reflection on its image and reputation.
We recognise that the risks from bribery are a
growing concern in many countries across the world. NI-CO is continuing to ensure that high
ethical standards are maintained at all times and have implemented this policy and
procedures to maintain an ethical trading position and reduce the risk of bribery within the
company.
The aim of this policy is to limit the exposure of the Company to bribery by:

Nominating an Anti-Bribery contact person

Promoting an anti-bribery culture

Setting out a clear policy

Ensuring strict adherence to financial controls.

Undertaking a review of due diligence procedures

Training employees to understand, recognise and avoid the use of bribery by
themselves and others
o
Reinforcing existing policies:
o
Whistle blowing

Gifts and hospitality

Encourage all employees to be vigilant and report any suspicion of bribery

Investigate all instances of suspected or alleged bribery

Taking disciplinary action against any individual(s) involved in bribery
What is Bribery and Corruption?
Bribery and corruption has a range of definitions in law, but the fundamental principles apply
universally.
Bribery is the offer, promise, giving, demanding or acceptance of an advantage as an
inducement for an action which is illegal, unethical or a breach of trust.
Corruption is the misuse of public office or power for private gain; or misuse of
private power in relation to business outside the realm of government.
Acts of bribery or corruption are designed to influence the individual in the performance of
their duty and incline them to act dishonestly. For the purposes of this policy, whether the
payee or recipient of the act of bribery or corruption works in the public or private sector is
irrelevant.
What is a Bribe?
Bribes can take on many different shapes and forms, but typically they involve corrupt intent.
There will usually be a 'quid pro quo' – both parties will benefit. A bribe could be the:

Direct or indirect promise, offering, or authorisation, of anything of value

Offer or receipt of any kickback, loan, fee, reward or other advantage

Giving of aid, donations or voting designed to exert improper influence
The Policy
NI-CO prohibits the offering, the giving, the solicitation or the acceptance of any bribe,
whether cash or other inducement to or from any person or company, wherever they are
situated and whether they are a public official or body or private person or company by any
individual employee, agent or other person or body acting on NI-CO’s behalf in order to gain
any commercial, contractual or regulatory advantage for NI-CO in a way which is unethical
or in order to gain any personal advantage, pecuniary or otherwise, for the individual or
anyone connected with the individual. NI-CO recognises that market practice varies across
the territories in which it does business and what is normal and acceptable in one place may
not be in another. This policy prohibits any inducement which results in a personal gain or
advantage to the recipient or any person or body associated with them, and which is
intended to influence them to take action which may not be solely in the interests of NI-CO or
of the person or body employing them or whom they represent.
It is required that all personnel, including those permanently employed by NI-CO, temporary
agency staff and consultants:

act honestly and with integrity at all times and to safeguard the Company resources
for which they are responsible

comply with the spirit, as well as the letter, of the laws and regulations of all countries
in which NI-CO operates or hopes to operate, in respect of the lawful and responsible
conduct of business

respect NI-CO’s customers, suppliers and other parties with whom it must interact to
achieve its objectives by conducting business in an ethical, lawful and professional
manner.
Procedures and Guidelines:
1. Board members, employees, associate consultants shall report any attempt at
bribery which comes to their attention, whether it consists of an approach to one of
them or an act done by an associated third party. In the first instance the report
should be made to the Company Secretary.
2. Under no circumstances should a person who reports a suspicion of bribery be
subject to victimisation for making a bon fide report, whether or not the suspicion
turns out to be justified. Please refer to NI-CO’s Whistle blowing policy for guidance.
3. Hospitality – NI-CO can continue to provide bona fide hospitality, promotional or
other business expenditure as long as it is reasonable and proportionate to the
business. Please refer to NI-CO’s Gifts and Hospitality