Anti-Corruption and Bribery Policy

Effective Date: January 2024

1. About This Policy

1.1 Ikshana is committed to conducting its business with honesty, integrity, and transparency. We take a zero-tolerance approach to bribery and corruption and are fully committed to acting professionally and ethically in all our business dealings and relationships.

1.2 The purpose of this policy is to:

(a) Outline the responsibilities of Ikshana and all individuals working on its behalf in observing and upholding our stance against bribery and corruption;

(b) Provide clear guidance on recognising, preventing, and responding to bribery or corruption; and

(c) Establish a framework for reporting concerns or breaches in line with our ethical standards.

1.3 This policy should be read in conjunction with any future Whistleblowing Policy, Gifts & Hospitality Guidelines, or employment contract clauses introduced by Ikshana.

1.4 Breaches of this policy by employees may result in disciplinary action, including dismissal for gross misconduct. Non-employees (such as contractors or partners) may face immediate termination of engagement.

1.5 Ikshana will ensure that all third parties acting on our behalf comply with legal obligations no less stringent than those set out in this policy.

2. Who Must Comply

This policy applies to all persons working for or on behalf of Ikshana, including employees, directors, officers, agency workers, interns, contractors, consultants, volunteers, and any third-party representatives.

3. What Is Bribery?

3.1 A bribe is any financial or other advantage offered, promised, given, requested, or accepted to influence a decision improperly or reward improper performance. Examples include:

  • Cash payments

  • Gifts or hospitality

  • Employment offers

  • Contract awards

  • Personal favours

3.2 Bribery includes both offering and accepting improper benefits.

3.3 All forms of bribery are strictly prohibited. If you are unsure whether a particular action constitutes bribery, seek advice from the Chief Operating Officer – Operations.

3.4 The following actions are not permitted:
(a) Offering or receiving any benefit in exchange for business advantage;
(b) Accepting an offer from a third party that is linked to securing preferential treatment;
(c) Making facilitation payments to public officials;
(d) Offering or accepting gifts or hospitality during procurement or contract negotiations;
(e) Retaliating against someone who refuses to engage in bribery or reports wrongdoing.

4. Gifts and Hospitality

4.1 Ikshana permits reasonable and proportionate hospitality for legitimate purposes such as building relationships and promoting our services.

4.2 Gifts or hospitality should not:

  • Be lavish or excessive;

  • Create a sense of obligation;

  • Be seen as a reward or inducement;

  • Include cash or cash equivalents;

  • Be given in secret.

4.3 Promotional items of low value (e.g. branded pens or notebooks) may be exchanged, provided they do not breach the above standards.

4.4 Site-specific policies on gifts from residents or families will be introduced in due course and will supersede general provisions where applicable.

5. Record-Keeping

5.1 Any gifts or hospitality received or given must be reported to the appropriate manager and recorded. Central office staff must notify the Chief Financial Officer (CFO) in writing.

5.2 All financial records must be accurate, transparent, and complete. No "off-book" accounts should be maintained to hide improper payments.

6. Reporting Concerns

6.1 If you are offered a bribe, asked to make one, or suspect any breach of this policy, you must report it immediately to the Chief Operating Officer – Operations.

6.2 Alternatively, you may email your concern confidentially to compliance@ikshana.co.uk.

6.3 Retaliation against anyone who reports a genuine concern will not be tolerated and will be treated as a disciplinary matter.

Review Schedule: This policy will be reviewed annually or sooner if legislative or operational changes require.