Anti-bribery and corruption—charitable and political donations

The following Practice Compliance practice note provides comprehensive and up to date legal information covering:

  • Anti-bribery and corruption—charitable and political donations
  • Charitable donations
  • Political donations
  • Definitions
  • Shareholder approval
  • Disclosure requirements
  • What is the risk?
  • Mitigating the risk
  • Total ban
  • Partial ban
  • More...

Anti-bribery and corruption—charitable and political donations

Charitable and political donations can give rise to higher risks of bribery and corruption. They can be (or be seen to be) bribes in disguise.

This Practice Note sets out what charitable and political donations are, the risk they carry and how to mitigate that risk.

Charitable donations

A charitable donation is a gift made by an individual or company to a non-profit organisation or charity.

It can include giving or providing cash, venues, equipment, personnel time or other benefit to a charity or to an individual or organisation nominated by or connected with a charity.

Although often grouped together (as they are here) charitable donations are usually very different in concept to political donations.

Most charities have no connection with politics and no decision making role or influence over procurement decisions, and so pose a minimal risk that a charitable donation could be corrupt or be perceived to be corrupt. Indeed, many organisations see charitable giving as an important part of their corporate social responsibility efforts.

But charitable donations do still carry risk; they can be a conduit for corrupt payments, eg a government official in negotiations with a business may disclose that they are on the board of a charitable organisation and request a donation made to the charity or a charity could be connected to a political party or a person with a

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