Our policy on anti-fraud, bribery, corruption and money laundering

Foothold is committed to reducing fraud, money-laundering, bribery and corruption to an absolute minimum and to reducing this minimum over time.

Foothold complies with applicable legislation including the Fraud Act 2006 and Charities Act 2022 which requires Trustees to safeguard the assets of the charity, and with applicable provisions of the Proceeds of Crime Act 2002, Terrorism Act 2000, Bribery Act 2010 and Money Laundering Regulations 2007 and all amending legislation.

As part of this commitment, we require our suppliers, community members, partners, contractors and agents to report any suspected or actual instances of fraud, money-laundering, bribery or corruption involving Foothold assets or staff.

Reports can be made through the link on this page or to the CEO on [email protected] / 07713644064.

A copy of our whistleblowing policy can be found here.

Fraud Prevention and Response Policy

The term ‘fraud’ is commonly used to describe the use of deception to deprive, disadvantage or cause loss to another person or party. This can include theft, the misuse of funds or other resources or more complicated crimes such as false accounting and the supply of false information. Fraud can be committed by someone within the charity (internal fraud) or by people that are not directly involved in the organisation (external fraud).

Fraud against charities takes many forms including:

• Fraudulent beneficiaries
• Bogus fundraisers
• Cyber-crime
• Fake charities
• Employee fraud
• Fraudulent grant applicants
• Procurement fraud
• Invoice fraud

Foothold:

• is committed to developing an anti-fraud culture and keeping the opportunities for fraud to the absolute minimum.
• will not penalise anyone for raising a concern in good faith, even if it turns out to be unfounded (HR11A Whistleblowing Policy). Any member of staff or volunteer who harasses or victimises someone for raising a concern in good faith will themselves be subject to disciplinary action.
• will investigate all instances of suspected fraud proportionately and appropriately as set out in this policy and the Fraud Response Plan.
• will maintain a system for recording: all reports of actual or suspected fraud, bribery and corruption; the action taken; and the outcome of any investigation. It will use this information to inform its review of the risks and the effectiveness of its controls.
• will always seek to take disciplinary and/or legal action against those found to have perpetrated, be involved in, or assisted with fraudulent or other improper activities in any of its operations.
• requires all staff, Trustees and volunteers to always act honestly and with integrity, adhering to policies and procedures and to safeguard the resources for which they are responsible and report any suspicions and/or incidents of fraud.
• will provide clear routes by which concerns can be raised by Staff, volunteers and Trustees and those outside of Foothold.
• will report all instances of fraud to the appropriate law enforcement, regulatory authorities and other third parties as appropriate.
• will make every effort to recover any wrongfully obtained assets.

Anti-money laundering and bribery policy

Money laundering is the practice of cleaning up money that has, for some reason, been obtained illegally. Often there is a complex trail involved so that the practice cannot be easily identified or traced. Money laundering can occur in many ways. It may happen by dispersing money through many different bank accounts (to hide its origins) but can also occur when the charity is used unwittingly as a “trading partner”. This could be directed at Foothold.

The purpose of this policy is to ensure Foothold’s compliance with applicable provisions of the Proceeds of Crime Act 2002, Terrorism Act 2000, Bribery Act 2010 and Money Laundering Regulations 2007 and all amending legislation, to assist law enforcement in combating illegal money laundering, and to minimise the risk of charity resources being used for improper purposes.

This policy aims to maintain the high standards of conduct which our Foothold currently enjoys. This will be achieved by ensuring that Foothold:

• is not used by third parties for the purpose of money laundering.
• does not receive bribes that are intended to influence Foothold decision making.
• is not subjected to corrupt, dishonest and or illegal behaviour.

How you can give feedback

If you need to report any concerns about suspected fraud, money-laundering or bribery with us, please submit your information via the form on this page.