Our approach
Virgin Money has a legal, moral and social responsibility to identify and deter anyone who wants to use our company to commit any sort of financial crime.
So we take a zero tolerance approach toward bribery and corruption. Under our Anti-Bribery and Corruption policy, we don’t allow the offering or receiving of any sort of bribe or corrupt payment. This applies to employees, agents, intermediaries, consultants, distributors, sub-contractors and suppliers working for us.
Our employees must not:
- Offer, give, receive or accept bribes.
- Use facilitation payments (usually small cash payments to secure or speed up a routine or necessary action, or service level).
- Make political contributions to gain an advantage in business.
- Make charitable donations or sponsorship payments in order to influence a third party decision or bring about illicit activity in Virgin Money’s favour.
- Offer, give, receive or accept gifts or hospitality – whether this is to reward, bring about or encourage preferential treatment, inappropriate behaviour or dishonest conduct.
Our employees must:
- Tell us about any conflicts of interest.
- Tell us about any gifts or hospitality they receive, and ask us to approve them.
- Take part in annual anti-bribery and anti-corruption training.
Virgin Money must carry out:
- An annual risk assessment and mitigate any identified risks.
- Appropriate checks on any third parties we deal with, and say no to anyone who does not operate in line with our high standards.
Our policies give clear guidance on how and when to declare gifts, and how to carry out and manage due diligence on an ongoing basis. They also offer guidance on sponsorship, charitable and political donations, including how to make sure they are approved, transparent and in line with the UK Bribery Act.
We regularly carry out risk assessments of our Anti-Bribery and Corruption framework.
Reporting concerns
We encourage employees worried about any sort of potential bribery or corruption to report this internally or by using our whistleblowing line. This gives colleagues a secure and confidential way to tell us about bribery or anything they feel is suspicious. We don’t tolerate victimisation or harassment of whistleblowers.
If one of our employees fails to comply with our Anti-Bribery and Corruption policy, we may take disciplinary action.
Third party relationships
When we engage in business relationships with third parties, we make sure they have the necessary skills and experience to provide the services we pay them for. All our business partners have to be reputable and reliable with a good track record, and they must charge a fair market price for their services.
We expect all our potential and existing business partners to have the same ethical standards as Virgin Money. They must also comply with the UK Bribery Act and be able to meet our due diligence requirements quickly and efficiently
Who does this notice apply to?
- Virgin Money (a trading name of Clydesdale Bank PLC).
- Virgin Money Personal Financial Service Ltd.
- Virgin Money Unit Trust Managers Ltd.
- Virgin Money Management Services Ltd.
What is anti-bribery and corruption?
Anti-bribery and corruption (AB&C) is how we describe the systems and controls we have in place to prevent Virgin Money or one of its employees breaching obligations under the Bribery Act 2010.
There are four key offences under the Act:
- Bribing another person.
- Being bribed.
- Bribing a foreign official.
- Failing to prevent bribery.
Laws and regulations
We are committed to maintaining an anti-bribery framework in line with the UK Bribery Act 2010 ('the Act') and with the Financial Conduct Association (FCA)'s Senior Management Arrangements, Systems and Controls.
We have also considered:
- The guidance issued by the British Bankers’ Association (BBA), based on the UK Ministry of Justice guidance to commercial organisations of adequate procedures under the Act.
- The FCA’s April 2015 Financial Crime – a guide for firms.