SPPA Bribery Policy


1. This paper sets out the Scottish Public Pensions Agency (SPPA) policy in relation to bribery. The policy takes account of the updating of bribery legislation in the Bribery Act 2010 and the Civil Service Code of Conduct and compliments existing Agency policies concerning Fraud and Whistleblowing.

2. As civil servants, all SPPA employees should be aware of the core values of integrity and honesty set out in the Civil Service Code and, in particular, the requirement that civil servants must not accept gifts or hospitality or receive other benefits from someone who might reasonably be seen to compromise our personal judgement or integrity. Similarly, we should not be influenced by improper pressures from others or the prospect of personal gain.

3. The Bribery Act 2010 applies to UK citizens, residents and incorporated entities in the UK. It modernises the law on bribery and creates offences for bribing another person and being bribed. In particular, it creates a new offence in respect of organisations that fail to prevent persons associated with them from bribing on their behalf.

4. SPPA recognises that over and above any criminal charges arising from specific acts of bribery, it may also tarnish our reputation, the reputation of the public sector and that of Scotland in general. SPPA therefore aims to limit exposure to bribery by:

  1. setting out an unambiguous anti-bribery policy that applies to all SPPA staff and all those acting on our behalf;
  2. communicating this policy to all staff and those acting on our behalf, and providing appropriate awareness and training;
  3. making it easy for staff to report concerns and encouraging them to be vigilant in helping to guard against bribery;
  4. maintaining robust policies and procedures that decrease the opportunity to offer or receive bribes and increase the likelihood of uncovering any such action; and
  5. making clear the obligation to self-report any incidence involving SPPA or a partner organisation under the Act.

The Policy

5. SPPA and SPPA staff will not:

  1. make or accede to threats;
  2. agree to accept or actually accept anything that an informed, reasonable third party could perceive as being:
    • an inducement for SPPA to act improperly;
    • a reward for SPPA acting improperly;
    • an offer, promise or give (whether directly or indirectly) of anything likely to be perceived to cause the same in others; and with any external organisation where reasonable suspicion exists that it may have committed offences under the Bribery Act.

6. SPPA and SPPA staff will:

  1. conduct the relevant due diligence on parties with whom we enter into business arrangements and make it clear from the outset of any such business that we will not tolerate any form of bribery; and
  2. make a self-disclosure to line management whenever anyone considers that there are reasonable grounds to believe that staff, contractors or business partners have committed a breach of the Act and co-operate fully with any ensuing investigation.

SPPA Commitment

7. The SPPA Senior Management Team, External Management Board and Audit Committee fully support the implementation and enforcement of the terms of this Policy throughout the organisation.

8. The SPPA Senior Management Team will formally review the Risk Assessments provided on bribery issues and confirm their contentment with the process annually.

9. As evidence of the commitment to detect and investigate as well as prevent bribery, the Audit Committee will ensure it maintains appropriate channels for reporting incidences. These can be found within the SPPA Whistleblowing policy.


10. Where the word staff is used in this policy, it includes all SPPA employees, its non-executive directors, secondees (inward and outward) and those employed by parties contracted to deliver services on our behalf. In this context, all staff are required to comply with the policy, the Act, the Civil Service Code and the relevant bribery and corruption laws in force in whichever jurisdiction in which they are engaged in business.

Training and Awareness

11. This policy will be drawn to the attention of staff annually via the Agency Intranet and team meetings (and will be included in induction material). Those considered in higher risk positions (namely: those working in Operational, Payroll and Finance post) will receive appropriate training in recognising and dealing with potential situations and sources of bribery and will be given adequate resources to help them prevent these situations from developing.


12. Directors across SPPA are responsible for enforcing procedures to prevent and detect all sources of fraud (including bribery) within their area of operation. As a minimum, they will include a statement of intent containing robust procedures within the manuals/operating instructions for pension administration, finance and procurement.

Reporting & Review

13. The Agency Senior Management Team (SMT) will monitor the policy and will hold (at least annually) a session dedicated to the topics of Fraud and Bribery.

14. SMT will review the control and reporting measures employed in order to check they are fit for purpose, consider the training and resources provided, request reports on the nature of overseas work conducted and new business considered. From this, it will report to the Board in the form of a risk assessment. In turn, the Board will consider if this process provides the assurance required.

Further Clarification

15. This policy is not designed to prohibit the following, provided they are reasonable:

  1. the offer of hospitality to customers/suppliers/external contacts that may reasonably be expected to be reciprocated;
  2. the presentation of ceremonial and token marketing gifts; and
  3. the use of legitimate, fast-track services available to anyone.

16. All managers are expected to recognise the implications of the policy and the limits of their discretion. Where they legally act outside set procedures, a clearly stated and defendable business case (noting the risks of such actions) must be presented in writing to the Senior Management Team and the Director responsible for the procedures.

17. This policy will be maintained by the Agency Finance Directorate.

Link to Scottish Government Website