1 Purpose and prohibition
This policy prohibits benefits that influence an Association decision or appear to be offered in return for one. It covers cash, vouchers, services, hospitality, travel, discounts, promises and benefits to relatives. Requesting, offering or accepting a bribe or facilitation payment is prohibited regardless of its value or description. (1)
2 Gifts that must be refused
Cash, personal vouchers, gifts linked to assistance, procurement, recruitment or oversight decisions, and secret or conditional gifts are refused. Gifts must not be divided or redirected to relatives to evade the prohibition. If safe return is impossible, the gift is handed to the Association with the circumstances recorded, without personal use until its disposal is decided.
3 Disclosure and assessment
Recipients immediately disclose the donor, estimated value, relationship and pending decision to the Secretary. Where a conflict exists, participation in the decision stops until it is resolved. Gifts are assessed by purpose, timing, frequency and proportionality; no financial threshold makes acceptance automatically lawful.
A protocol souvenir may be accepted in the Association’s name with approval from an independent authorised person and recorded as an institutional asset or item where necessary. Recipients cannot approve their own gifts. Gifts to the Chair are referred to disinterested Board members. Justified professional hospitality, its purpose, attendees and expenditure approval are recorded. (2)
4 Donations and sponsorship
Donations and sponsorship must not conceal personal benefits or favour a supplier or beneficiary. Institutional contributions follow donation, due-diligence and allocation procedures. Staff must not promise benefits outside the contract and permit. Support does not guarantee an assistance decision or contracting opportunity.
5 Responding to pressure
Improper benefit requests are refused and documented without compromising safety, and reported to Compliance, using an alternative channel where it has a conflict. Evidence is preserved and legal review sought on reporting to authorities, respecting reporting duties and prohibitions on tipping off suspects where applicable.
6 Oversight and correction
The register is reviewed periodically for repeated donors or links to contracts and decisions. Related expenses and donations are checked. Breaches are addressed through fair procedures, recovery of benefits where permitted and correction of affected decisions. Repayment does not replace legal accountability.
References in the approved document
- The Association’s approved 2026 Articles of Association, Articles 73–74; Conflicts of Interest Policy NABDA-COI-001. This document sets internal implementation controls without changing a higher-level legal requirement or competence.
- Applicable criminal legislation on bribery and abuse of position. The policy applies a stricter internal control without creating a criminal classification or legal exemption amount. This document sets internal implementation controls without changing a higher-level legal requirement or competence.