Anti-Bribery and Corruption Policy

Policy Statement

To establish controls to ensure compliance with all applicable anti-bribery and corruption regulations, and to ensure that Change's business is conducted in a socially responsible manner.

We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery and corruption.

We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate.


To set out our responsibilities, and of those working for us, in observing and upholding our position on bribery and corruption; and provide information and guidance to those working for us on how to recognize and deal with bribery and corruption issues.

It is a criminal offence to offer, promise, give, request, or accept a bribe. Individuals found guilty can be punished by up to ten years' imprisonment and/or a fine. As an employer if we fail to prevent bribery we can face an unlimited fine, exclusion from tendering for public contracts, and damage to our reputation. We therefore take our legal responsibilities very seriously. In this Policy, third party means any individual or organization we come into contact with during the course of your work and includes actual and potential clients, candidates, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

Who must comply with this policy?

This policy applies to all persons working directly for Change or on our behalf in any capacity, including employees at all levels, directors, , agency workers, , volunteers, interns, agents, contractors, external consultants, third party representatives and business partners, sponsors, or any other person associated with us, wherever located .

Defining and explaining bribery and corruption

  • Bribery is offering, promising, giving or accepting any financial or other advantage, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage.
  • An advantage includes money, gifts, loans, fees, hospitality, services, discounts, and the award of a contract or anything else of value.
  • A person acts improperly where they act illegally, unethically, or contrary to an expectation of good faith or impartiality, or where they abuse a position of trust. The improper acts maybe in relation to any business or professional activities, public functions, acts in the course of employment, or other activities by or on behalf of any organization of any kind.
  • Corruption is the abuse of entrusted power or position for private gain.