Anti-Fraud Bribery and Corruption Policy

Version 2.0 July 2025

  1. Scope
  2. Policy statement
  3. Definitions
  4. Hospitality, Entertainment and Gifts
  5. Compliance
  6. Responsibilities
  7. Equality, diversity and inclusion
  8. Related documents
  9. Legislation and regulation
  10. Review

1 - Scope

1.1 The purpose of this Policy is to ensure that all staff and board and committee members are aware of the Group’s approach to countering fraud, bribery and corruption.

1.2 The aim of the Policy is to ensure that timely and effective action is taken to help minimise losses and increase the chances of a successful investigation and recovery.

1.3 The Policy is designed to enable the Company Secretary to:

  • immediately notify the internal auditors/Group Chief Executive, and the Regulator as appropriate; and
  • determine when and how to contact the police and establish lines of communication.

1.4 The Policy is designed to enable the Group to:

  • prevent loss;
  • minimise and recover losses;
  • assign responsibility for investigating an incident;
  • keep all relevant colleagues informed about the incident as the investigation develops;
  • Establish and secure evidence necessary for criminal and/or disciplinary action;
  • review the reasons for the incident, the measures taken to prevent a recurrence and determine any action needed to strengthen future responses to fraud; and
  • help to promote an anti-fraud culture by making it clear to employees, customers and other stakeholders that the Group will vigorously pursue all cases of fraud, taking approp

2 - Policy statement

2.1 The Group is committed to maintaining the highest possible standards in good governance. Bribery is illegal and the Group takes a zero tolerance approach to bribery, fraud and other irregularities. Staff have an integral role in ensuring the Group acts with integrity and that any incidents are responded to professionally and swiftly. The Group will not knowingly work with any organisations or individuals who tolerate bribery or fraud.

2.2 The Group Board has delegated responsibility to the Audit and Risk Committee (ARC) to ensure there are robust policies in place that provide clear guidance on the actions to be taken in the case of either suspected or actual fraud or other related impropriety.

2.3 ARC has responsibility for overseeing the reporting and investigation of suspected or confirmed incidences of fraud, corruption and/or impropriety.

2.4 ARC also has responsibility for reviewing policies implemented in relation to fraud and corruption.

2.5 All employees are expected to follow the approved procedures for internal control including Standing Orders and Financial Regulations that will help to minimise the opportunity for fraud.

  • Any suspicion of fraud, bribery or corruption must be reported to the Company Secretary immediately on its detection or suspicions being raised.

3 - Definitions

Fraud - Defined as any deliberate use of deception or dishonesty to disadvantage or cause loss (usually financial) to another person or any of the companies/subsidiaries within the Group. Fraud may be carried out by staff, Board members or other parties such as contractors, service providers or customers

Bribery - When a person offers, gives, receives or solicits a financial (or other) advantage to another person with the intention of inducing or rewarding that person to act improperly. For the purpose of clarity, a bribe need not have been given or paid for an offence to have been committed. Agreeing to or being complicit in the payment or receipt of a bribe constitutes bribery even where this arrangement is not completed.

Corruption - Involves using your position of trust for personal gain – for example, accepting money from a customer to ignore rent arrears, or using your influence to get a job for a friend or relative.

Relevant Fraud legislation

3.1 Fraud legislation defines the following main types of fraud:

  • Fraud by false representation (s.2 Fraud Act 2006)
  • Fraud by failing to disclose information (s.3 Fraud Act 2006)
  • Fraud by abuse of position (s.4 Fraud Act 2006)
  • Participation in a fraudulent business (s.9 Fraud Act 2006)
  • Obtaining services dishonestly (s.11 Fraud Act 2006)
  • Cheating the public revenue (common law)
  • False accounting (s.17 Theft Act 1968)
  • False statements by company directors (s.19 Theft Act 1968)
  • Fraudulent trading (s.993 Companies Act 2006)

3.2 Examples of potential frauds are:

  • A job applicant or employee giving a false work history or claiming to have qualifications that they do not have. (This applies to 'material falsehoods’ – that is, if they had filled in the application form truthfully, we would not have given them the job.)
  • An employee claiming more mileage on their expenses claim than they had actually driven.
  • Property allocation and tenancy fraud (including Right to Buy), theft or misuse of assets/stock, sale of property at less than market value (see also Tenancy Fraud Policy and Procedure).
  • Unauthorised use or misuse of any property, equipment or materials owned by the Group or any of its subsidiaries.
  • Diverting restricted or designated funds to other projects within the company but continuing to record them as payments for their restricted/designated purpose.
  • Falsifying data/information to appear eligible for grants or to appeal to investors.

The Bribery Act

3.3 There are four principal offences under the Bribery Act 2010 (the Act):

  • offering, promising, or giving bribes;
  • requesting, agreeing to receive, or accepting bribes;
  • bribery of a foreign public official; and
  • the corporate offence - failure of a commercial organisation to prevent bribery.

3.4 The Act includes a strict liability offence for organisations where someone associated with an organisation, including Board and committee members, staff, contractors and involved residents, agents or sub-contractors, commits an act of bribery to obtain or retain business or a business advantage.

3.5 Strict liability means that the Group may be liable in law without a finding of fault. Liability only needs proof that a bribe was made by someone associated with the Group with the intention of giving the Group a business advantage. This applies whether or not the Group encouraged such action or was aware of it. The responsibilities under the Act therefore need to be taken extremely seriously.

4 - Hospitality, Entertainment and Gifts

4.1 This Policy must be read in conjunction with the Group’s Standing Orders, Codes of Conduct for Board Members and employees and the Gifts and Hospitality Policy, particularly in relation to:

  • approval of levels of hospitality, entertainment and gifts;
  • the need to declare hospitality, entertainment and gifts; and
  • the need to keep a register of declarations.

4.2 This Policy does not prohibit the giving or receiving of reasonable, proportionate and appropriate hospitality, entertainment or gifts to or from people and organisations the Group works in partnership with. There are circumstances where the acceptance of hospitality, entertainment or gifts is in accordance with established business practice, or where the acceptance of gifts or hospitality is difficult to avoid without causing offence. Any such hospitality, entertainment or gifts should be given and received openly and transparently.

4.3 Board and committee members, staff and involved residents should generally not receive or offer hospitality, entertainment and gifts from or to persons or organisations that may be in a position to benefit from actions or decisions taken by the Group.

4.4 Hospitality, entertainment and gifts cannot be given or received if done so with the intention of influencing someone to give the Group business, influencing the Group to award business or to reward the provision or retention of business or business advantage.

4.5 Any hospitality or gifts given should be reasonable and proportionate and designed to:

  • cement or improve relationships;
  • show genuine appreciation for services;
  • improve the Group’s image; and/or
  • market products or services.

4.6 Recipients should never be given the impression that they are under an obligation to confer a business advantage on the Group because of the hospitality, entertainment or gifts offered.

4.7 Hospitality, entertainment or gifts should not be offered to, or accepted from, government officials or representatives, or politicians or political parties, without the prior approval of the Chief Executive.

4.8 You should never give, promise or offer a payment, hospitality, entertainment or gift to a government official, agent or representative to expedite or facilitate a routine procedure (for example, to speed up a planning application).

4.9 If you suspect that hospitality, entertainment of gifts are being offered or provided with an expectation that a business advantage will be provided by the Group in return, then you must not accept it and you must report this to the Company Secretary immediately.

4.10 Any offer of hospitality, entertainment or gifts (including both accepted and declined) and offered by you (subject to you having the necessary approval to make such an offer) should be declared appropriately as set out in the Standing Orders and Codes of Conduct for Board Members and staff. Unofficial payments or kick-backs should not be offered or accepted under any circumstances.

Expenses and Payments

4.11 Any expenses claims you make must be in accordance with:

  • For Board and committee members – the Board members’ Remuneration, Payments, Expenses and Benefits Policy;
  • For staff, the Group’s Employee Code of Conduct;
  • For involved residents, the Group’s Resident Involvement Strategy

4.12 Such claims must be properly recorded and supported by receipts (other than in exceptional circumstances).

Dealings with third parties

4.13 If you make payments to third parties, details of such payments must be properly recorded and receipted.

4.14 In making any such payments, you should consider what these payments are for and whether they are reasonable and proportionate.

4.15 You must make all suppliers / contractors and business partners you deal with ware that the Group takes the prevention of bribery and corruption very seriously and that it will not be tolerated.

4.16 No hospitality, entertainment or gifts should be offered to or accepted from any organisation for which the Group is tendering for a contract during the tender process.

Charitable donations

4.17 The Group will only make charitable donations that are legal and ethical. No donation will be offered or made without the prior approval of the Group Chief Executive or Chief Financial Officer.

Political donations

4.18 The Group will not make donations to political parties.

Practical procedures

4.19 All payments will be recorded, to make sure that there can be no concealment of improper payments.

Training

4.20 Board and Committee members, employees and involved residents will receive training on anti-corruption measures and the requirements of this policy, and all new Board and Committee members and employees will receive anti-bribery training as part of their induction.

4.21 All of this training is mandatory for all Board and committee members, employees and involved residents.

Contractors, consultants and working with third parties

4.22 The Group has reviewed its standard commercial contracts to ensure there is provision for termination where a contractor providing services, agent, or consultant commits bribery.

4.23 The Group will carry out appropriate due diligence on agents, consultants and contractors (including in relation to potential joint venture arrangements), including taking and checking references, checking ownership, checking details of other directorships or partnerships, reviewing financial statements and accounts, incorporating checks into interviews, reviewing any judicial or regulatory findings and keeping a record of all checks carried out. In carrying out such due diligence, the Group will have regard to the potential bribery risks posed by its relationship with such agents or contractors, especially where they operate in higher risk sectors (e.g. construction) where the project is of higher value and/or longer duration.

4.24 The Group will require contractors to put in place appropriate anti-bribery procedures both internally and with sub-contractors (if applicable), including, if appropriate, bribery prevention training for employees.

4.25 Where any consultant, agent or contractor offers hospitality on the Group’s behalf, the Group will ensure such hospitality is only offered where appropriate, reasonable and proportionate. This may include providing such third parties with criteria for the provision of hospitality.

4.26 In employing consultants, contractors or agents, the Group will provide a clear statement of the services to be provided and any relevant costs, commissions and fees (except where this is clear from the contract with that third party).

Tendering

4.27 The Group will provide appropriate training to employees involved in tendering exercises to enable them to identify potential bribery risks.

4.28 The Group will require all contractors for the provision of services to demonstrate a commitment to tackling bribery.

4.29 The Group will include a statement about its stance towards bribery in all tender documents.

5 - Compliance

5.1 A Fraud, Loss, Bribery and Whistleblowing Register will be maintained by the Company Secretary. All incidents of actual or attempted fraud, loss and bribery will be recorded. The register will also indicate the actions taken after the event and the systems involved, in order to assist in the prevention of any recurrences.

5.2 The Register shall be available for inspection by the Board, and all reported matters shall be reviewed at each ARC meeting. The Group will also submit, as required, an annual fraud report to the Regulator of Social Housing.

5.3 Compliance with this policy (and related procedures) shall be monitored by the Company Secretary on a quarterly basis, through the production of a compliance report to EB/ARC.

6 - Responsibilities

6.1 Everyone within the Group has a general responsibility to report immediately any act of attempted or detected fraud or theft. This includes a reasonable suspicion of attempted fraud or suspicions of irregularities in any function of the Group.

Audit and Risk Committee - A report of fraud (including tenancy fraud) and loss shall be given at each meeting of the ARC and a written report presented on significant matters. The Chair of ARC will confirm that management has taken appropriate action and that it was taken in a timely and robust manner. If the matter is significant as determined by the Chair, the Chair will convene a special meeting of ARC.

Executive Board - It is the responsibility of the Executive Board members to take all reasonable actions to prevent and detect fraud within their areas of responsibility. This includes:

  • Taking action to provide assurance that the activities of the Group are conducted honestly and that assets are safeguarded, including assessing the risk involved in their operational areas;
  • Establishing arrangements designed to deter fraudulent, corrupt or other dishonest conduct and ensuring that these arrangements are complied with; and
  • Implementing new controls to reduce the risk of similar fraud or bribery where these have taken place, or a new or enhanced risk of fraud or bribery is identified.

Managers - All managers are responsible for ensuring there are procedures and systems of internal control in place to safeguard the resources for which they are accountable. Managers should identify all areas within their service that could be subject to fraud or impropriety. Managers must also satisfy themselves that adequate controls are in place to detect irregularities at the earliest opportunity.

Staff - All staff are responsible for ensuring their conduct complies with the Group’s Employee Code of Conduct. Staff must carry out their duties carefully and honestly following the Group’s procedures and guidance from their managers. These responsibilities include:

  • Complying with the law, the Group’s Financial Regulations and other policies;
  • Acting honestly in the handling and use of Group funds, including cash and the electronic payments systems, receipts, and contracting;
  • Being alert to the possibility that unusual events, behaviours or transactions could be indicators of fraud and/or bribery;
  • Reporting immediately any attempt by any individual to apply pressure or influence to subvert or fail to follow financial or other procedures;
  • Reporting details immediately through the appropriate channel if they suspect that a fraud has been committed or attempted, or they are aware of any suspicious acts or events; and
  • Cooperating fully with whoever is conducting internal checks, reviews or formal fraud investigations.

7 - Equality, diversity and inclusion

7.1 We will apply this policy consistently and fairly and will not discriminate against anyone based on any relevant characteristics, including those set out in the Equality Act 2010.

7.2 All matters considered under this policy will be investigated regardless of the individual’s position in the Group, a failure to notify any actual or suspected fraud activity may also be treated as a disciplinary matter.

8 - Related documents

  • Gifts and Hospitality Policy
  • Employee and Board Codes of Conduct
  • Whistleblowing Policy
  • Disciplinary Policy
  • Anti-Money Laundering Policy
  • Tenancy Fraud Policy & Procedure
  • Standing Orders

9 - Legislation and regulation

9.1 The legislation listed in this policy is not intended to cover all legislation applicable to this policy. To comply with clause 1.1 of the Regulator of Social Housing’s Governance and Financial Viability Standard, which requires adherence to all relevant law, SNG will take reasonable measures to ensure compliance with all applicable legislation by reviewing policies and procedures and amending them as appropriate. Any queries relating to the applicable legislation should be directed to the policy owner.

9.2 Relevant legislation and regulation that is directly applicable to this policy.

  • Economic Crime and Transparency Act 2023 Fraud Act 2006Bribery Act 2010
  • RSH Code of Conduct

10 - Review

10.1 This document will be reviewed every 3 years, or sooner if significant changes occur in the relevant legal or operational landscape.

10.2 The review of this policy will be based on applicable legislation and regulatory requirements and a consideration of sector best practice.