The Trustees and the Director of the Poetry Society (Charity No 303334), recognise their duty to ensure that the charity is compliant with the law.
Against the background of the Poetry Society’s work as defined in its constitution; the fact that the Society operates only within the United Kingdom and is not currently involved in commercial contracts, the Trustees consider that the risk of the charity contravening The Bribery Act 2010 to be very small.
For the avoidance of doubt however, the Poetry Society expressly prohibits anyone associated with the charity (including Trustees, and staff) from offering, giving, soliciting or accepting any bribe (of whatever nature) in order to advantage in any way the charity, themselves or persons/businesses connected with either.
Trustees require that any suspicion of activities of this nature to be brought to the attention, as appropriate, of the Director or Chairman or, should either be implicated, to the attention of the Poetry Society Board of Trustees who will designate an Appointed Sub Committee to review the matter. Evidence of such activity will be used in disciplinary misconduct action against the staff member, or will result in the Trustee being required to demit office. Any individual convicted of an offence under the Bribery Act 2010 in connection with activities not relating to the charity will be similarly treated. Businesses convicted of any such offence will not subsequently be used by the Poetry Society.
The giving or receiving of appropriate hospitality, or small gifts by way of “thank you-s” are not prohibited by this policy if reasonable in context and not initiated with any intention to improperly influence any decision or process, or provide reward for doing so. However, all Trustees and staff will be required once a year to complete a ‘conflict of interest form’ so that their duties include avoiding any situation where a conflict may arise, rather than just the conflict itself.
For the purposes of transparency, the Director of the Poetry Society will maintain a register of hospitality and gifts, given or received, with an individual value of £50 or more. Trustees, staff and other agents acting on behalf of the charity are requested to notify the Director of any gifts or hospitality received or given in excess of this amount, in connection with their activities with the charity.
The Trustees will review this policy and its associated procedures annually, and in the event of any developments which might indicate risk of contravention of the Act.
Copies of this policy will be provided to all Trustees and staff, as well as to all individuals or businesses contracted to act on behalf of the charity. This policy will also be posted on the Poetry Society website.