1. Purpose and scope

This policy applies to all trustees, staff, volunteers, and anyone acting on behalf of The Healing Hubs.

Bribery is the offering, promising, giving, accepting, or soliciting of an advantage as an inducement for action that is illegal, unethical, or a breach of trust. It is a criminal offence under the Bribery Act 2010.

2. Our commitment

The Healing Hubs has a zero-tolerance approach to bribery and corruption in any form.

We are committed to acting professionally, fairly, and with integrity in all our dealings and relationships.

We will uphold all applicable laws relating to anti-bribery and anti-corruption wherever we operate.

3. Gifts and hospitality

We recognise that the giving and receiving of gifts and hospitality is a normal part of building relationships with partners, funders, and supporters.

However, gifts and hospitality must never be used to gain an improper business advantage or to influence a decision.

Only gifts of nominal value (up to £5) may be accepted. Any offer of a gift — regardless of whether it is accepted — must be reported to the Team Manager and recorded in the gifts register.

Gifts of cash or cash equivalents (such as vouchers) must never be accepted.

4. Facilitation payments

Facilitation payments — unofficial payments made to secure or speed up routine actions — are a form of bribery and are strictly prohibited.

If you are asked to make a facilitation payment, you must refuse and report the request to the Team Manager immediately.

5. Reporting concerns

Any concerns about bribery, corruption, or inappropriate gifts should be reported to the Team Manager or, if the concern involves the Team Manager, to the Chair of Trustees.

Reports can also be made under our Whistleblowing Policy, which provides protection for those raising concerns in good faith.

The Healing Hubs will not tolerate any retaliation against anyone who raises a genuine concern.

6. Consequences of breach

Any breach of this policy will be treated as a serious disciplinary matter and may result in dismissal or termination of a volunteer's role.

Breaches may also be reported to the relevant authorities, including the Charity Commission and the police.

7. Review

This policy will be reviewed annually by the Board of Trustees or following any relevant change in legislation.