1. Policy Statement

1.1. This policy is a statement of principles outlining Mary’s Meals’ commitment to preventing bribery and corruption in our organisation. The Mary’s Meals aspiration is that all network entities implement local policies and processes to achieve this in line with local laws, regulations and guidance. 

1.2. The Anti-Bribery & Corruption policy aligns with other global policies including Whistleblowing, Protection of Funds and Modern Slavery. 

1.3. Mary’s Meals is committed to: • a zero-tolerance approach to bribery and corruption;

• acting fairly, honestly and openly in all our dealings and relationships wherever we operate;
• maintaining the highest standards of ethical behaviour in all our activities; and
• upholding all laws relevant to countering bribery and corruption in the jurisdictions in which we operate. 

1.4. The purpose of this document is to:

• Outline Mary’s Meals’ zero tolerance approach to bribery and corruption.
• Define behaviour which amounts to corruption and set out responsibility for reporting.
• Set out our responsibilities, and of those working for and on our behalf, in observing and upholding our position on bribery and corruption.
• Provide information and guidance to those working for and on our behalf on how to recognise and deal with bribery and corruption issues. 

2. Scope / Applicability 

2.1. This policy is applicable to MMI, National Affiliates and Programme Affiliates. It applies to all employees, directors, volunteers, agents, partnering agencies, consultants, contractors and to any other people or bodies associated with Mary’s Meals, within all regions, areas and functions, wherever located. 

2.2. Mary’s Meals expects external parties such as suppliers, partners and contractors to adhere to the general principles of this policy but also to have or put in place similar policies and procedures if possible. In any event, arrangements with programme partner organisations are subject to clear contractual terms, including specific provisions that require the partner organisation to comply with minimum standards and procedures relating to anti-bribery and corruption. 

3. Who is Responsible for this Policy? 

3.1. The MMI Board and each Affiliate Board (subject to the terms of their Scheme of Delegation) have overall responsibility for ensuring this policy, and all local policies and procedures flowing from this, comply with all legal and ethical obligations, and that all those under the scope comply with it. 

3.2. Each Mary’s Meals’ entity should put in place suitable arrangements for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering bribery and corruption. 

3.3. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and those policies and procedures flowing from this. 

4. What is Bribery and Corruption? 

4.1. 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. 

4.2. An advantage includes money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or anything else of value. 

4.3. 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 may be 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 organisation of any kind 

4.4. Corruption is the abuse of entrusted power or position for private gain. 

5. What must not be done: 

5.1. It is not acceptable for an individual, or someone acting on their behalf, to: 

a) give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business, regulatory or personal advantage will be received, or to reward a business, regulatory or personal advantage already given; 

b) give or accept a gift or hospitality during any commercial contract discussions, negotiations or tender process, if this could be perceived as intended or likely to influence the outcome; 

c) accept a payment, gift or hospitality from a third party that may be known or suspected is offered with the expectation that it will provide a business, regulatory or personal advantage for them or anyone else in return; 

d) accept hospitality from a third party that is unduly lavish or extravagant under the circumstances;  

e) offer or accept a gift to or from government officials or representatives, or politicians or political parties; 

f) threaten or retaliate against another individual who has refused to commit a bribery offence or who has raised concerns under this policy; 

g) accept a charitable donation solely given on the basis of receiving a non-charitable benefit or 

h) engage in any other activity that might lead to a breach of this policy. 

5.2. Behaviour which amounts to corruption that is prohibited by this policy includes, but is not limited, to the following: 

a) Paying or offering a bribe – where a person improperly offers, gives or promises any form of material benefit or other advantage, whether in cash or in kind, to another in order to influence their conduct in any way. 

b) Receiving or requesting a bribe – where a person improperly requests, agrees to receive or accepts any form of material benefit or other advantage, whether in cash or in kind, which influences or is designed to influence conduct in any way. 

c) Receiving or paying a so-called ‘facilitation’ payment – where a person improperly receives something of value from another party for performing a service or other action that they were required by their employment to do anyway. 

d) Nepotism or patronage – where a person improperly uses their employment or other position with Mary’s Meals to favour or materially benefit friends, relatives or other associates in some way. 

e) Embezzlement - where a person improperly uses funds, property, resources or other assets that belong to Mary’s Meals or a connected organisation or individual. 

f) Receiving a so-called ‘Kickback’ Payment –where a person improperly receives a payment to secure or expedite a routine or necessary action, or as a result of their involvement in a corrupt bid or tender process. 

g) Collusion – where a person improperly colludes with others to circumvent, undermine or otherwise ignore Mary’s Meals’ rules, policies or guidance. 

h) Abuse of a position of trust – where a person improperly uses their position within Mary’s Meals or a connected organisation to materially benefit themselves or any other party. 

5.3. Attempted corruption is as serious as the actual acts and will be treated in the same way under this policy. 

6. Reporting 

6.1. All Mary’s Meals staff and volunteers across the Network have a duty to protect Mary’s Meals’ assets from any form of corruption. 

6.2. The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those who are part of the Mary’s Meals network, in any capacity. Everyone is required to avoid any activity that might lead to, or suggest, a breach of this policy and leaders across the network are required to make this clear to all involved with Mary’s Meals. 

6.3. If there is a belief or suspicion that a conflict with this policy has occurred, or may occur in the future, the Global Whistleblowing Statement will be of relevance and a report in line with this should be made as soon as possible, following the relevant local reporting process. 

7. Early Reporting 

7.1. Everyone should be encouraged to raise concerns about any issue or suspicion of bribery or corruption at the earliest possible stage. 

7.2. If there is a question about whether a particular act constitutes bribery or corruption, this should be raised it with the relevant manager. 

7.3. Individuals who refuse to accept or offer a bribe, or who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. 

7.4. We are committed to ensuring no one suffers any demonstrable detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. 

8. Local policies and procedures 

8.1. All Mary’s Meals entities must ensure that this policy has been read, understood, and complied with, and commit to creating and implementing local policies and processes to support the principles outlined in this policy, which should be acknowledged by all. 

8.2. All Mary’s Meals entities are encouraged to provide training to all relevant staff or volunteers on local policies flowing from this, and to ensure a high level of understanding of the need for checks to prevent bribery and corruption. 

8.3. Breaches of this policy, or any local policies and procedures, should be taken seriously and dealt with appropriately by the relevant Mary’s Meals entity.