Serco is committed to the highest standards of integrity, honesty, openness and professionalism in all its activities wherever they are undertaken.  As an employee of Serco, you are bound to comply with the Serco Management System and Code of Conduct, including any local operating procedures (as may be updated).  This form highlights some of your obligations in relation to Anti-Bribery, Corruption and Fraud. By completing and signing this form, you acknowledge that you understand these requirements.

 
Serco Management System

The Serco Management System defines the way we run our business. It is your responsibility to know and understand the policies and standards that make up the Serco Management System. This includes the Serco Code of Conduct, which defines what is expected of all Serco employees. No code can address every possible situation. Where a specific act is not mentioned or you are not sure what action to take, you should always seek guidance from your manager. 

 

Political Activity and Payments

Serco maintains a position of impartiality with respect to political activity and as such no Serco employee is to make any contributions, whether with funds, time or resources from Serco for political purposes.  Any opinions expressed by employees in their own time will not represent Serco's position, and should not be presented as doing so.

 

Trade and Industry

Employees participating in trade or industry events or associations must make it clear that they are not speaking on behalf of Serco unless they have been authorised to do so by senior management.

 

Charitable Donations and Corporate Sponsorships

Serco supports and contributes to the social and economic wellbeing of the communities we work in. Any use of company resources (whether monetary donations or those in kind, such as use of company assets or resources) in this regard must be pre-approved by your manager and reported by them in the Quarterly Corporate Social Responsibility submissions.

 

I.T. Acceptable Use Policy

The Serco IT Acceptable Use Policy sets out the behaviours that you are required to adopt, including the use of the internet, social media and email (whether or not they are provided by Serco) to access, process and publish information either owned by or about Serco.

 

Previous Government Employees

Serco will never expect nor condone former government employees using their previous position and / or contacts in a manner that is contradictory to Serco’s governing principles and policies. If you are a previous government employee, from any country, please declare this on the last page of this form.

 

Conflicts of Interest

A conflict of interest is a situation in which an employee has competing professional or personal interests. Such competing interests can make it difficult for individuals to fulfil their duties impartially. A conflict of interest may exist even if no unethical or improper act results from it.  Examples may include:

• Employee acting as advisor to a customer when Serco is competing for work from that customer.
• Ownership by an employee, their partner, spouse or family member of a significant financial interest (5% of outstanding stock of a public company or any ownership interest in a company that is not publicly traded) in a competitor of Serco, or in a customer, consultancy, subcontractor, supplier or other business partner of Serco.
• A spouse, partner or family member is employed by any other Serco business or joint venture. 
• A spouse, partner or family member is employed by a direct competitor to any other Serco business or joint venture.
• A spouse, partner or family member is employed by a supplier of goods or services to Serco.

Serco employees are required to declare any known or suspected conflicts of interest at the commencement of employment and as any conflicts become known during employment, so they can be properly managed by both the company and the individual. This should be done using the Employee Acknowledge Form. The majority of conflicts will require no further action except where circumstances may change.

 

Gifts & Hospitality

Gifts, gratuities or entertainment of any kind in relation to your employment with Serco, must not be requested, given or accepted if this action could be reasonably regarded as unduly influencing the recipient or creating a business obligation on the part of the recipient.

Before offering or accepting a gift or some kind of hospitality to or from a client, customer, partner or supplier, please refer to the below table.  A Gifts & Hospitality Notification Form must be completed and once approved by your line manger sent to SME Assurance function.

 

 

Confidential Information

Serco employees may at times be privileged to sensitive / confidential information relating to Serco / customers / partners / suppliers, which has not been published or which is not otherwise ‘generally available’.  Where this is applicable, employees will not use this information unethically for personal gain.  For example; Buying, selling or otherwise dealing in shares of Serco or any respective customers / partners / suppliers before a significant contract award announcement, without obtaining clearance from their line manager to deal in advance.

 

FOR NEW DECLARATIONS - Please provide as much detail as possible of known or suspected Conflicts of Interest.

Some example Conflicts are:

Situations where a someone is placed in a position where their duty to act independently and/or exercise their professional judgement ethically and without prejudice may be, or appear to be, compromised by self-interest or a relationship with a third party.

Most conflicts of interest can be categorised as relating to:
a. Financial and Material Interests – where someone (or someone associated with them) could gain or lose financially because of the way the public officer fulfils their official duties. Examples of situations where such interests could give rise to a conflict of interest include:

• Property ownership
• Business partnerships
• Positions in companies
• Gifts and material goods
• Shares
• Debts
• Hospitality
• Travel.

b. Non-Financial and Partiality Interests – where someones personal involvements, relationships, obligations, values or attitudes may influence the way they carry out their official duties. Examples of situations where such interests could give rise to a conflict of interest include:

• Family relationships
• Friends (or adversaries)
• Religious and cultural obligations
• Membership of clubs, groups and associations
• Beliefs, values and attitudes
• Volunteer commitments

It is recognised that you may not be aware of all Serco customers, competitors, and suppliers at the time of completing this form (and therefore of any potential Conflicts of Interest you may have), however, as soon as you become aware of a potential conflict you must declare this by completing another acknowledgement form 

By signing this form I agree to:

- Be aware of and abide by all requirements outlined in this form, as well as all Serco policies, standards, procedures and Code of conduct.

- Update this disclosure throughout the period of my employment with Serco if a declared conflict is no longer applicable, or where a new conflict arises.

- Comply with any conditions or restrictions imposed by the Company to manage, mitigate or eliminate any actual, potential or perceived conflict of interest and / or commitment.

- I confirm that the information I have provided is true to the best of my knowledge and I understand that misrepresentation of information on this form may be grounds for suspension or immediate dismissal of   my employment.