Anti Bribery Policy

Passenger is committed to conducting business in an ethical and honest manner and is committed to implementing and enforcing systems that ensure bribery is prevented.


If you feel that you are being asked to do something that you are uncomfortable with in return for some form of reward, please speak immediately with the Head of People so that the company can take appropriate action.

Anyone suspected of taking part in acts of bribery or corruption will be subject to a full investigation, the result of which may result in disciplinary action being taken against the individuals concerned, as well as possible criminal charges under the provisions of the Bribery Act 2010.

However unlikely it might seem, bribery and corruption is an important topic to understand so that should it ever occur, you’re informed on the do’s and don’t. Whilst we’ve no doubt that all our employees are lovely trustworthy people, everyone is capable of a moment of weakness.

There may be times when the offer or acceptance of a reward to persuade another person to act dishonestly and/or in breach of the law seems too good to turn down. However, decisions have consequences. Should misconduct be discovered, our staff and our company be subject to criminal sanctions, including but not limited to prison time and heavy fines, under the Bribery Act 2010.

Passenger has a zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.

This document aims to draw clear lines to make it easy for all to understand what’s expected of them and how to raise the alarm if they suspect someone is behaving contrary to these guidelines.

Who is covered by the policy?

Our anti-bribery policy applies to all employees, for the avoidance of doubt this includes, but may not be limited to; temporary, fixed-term, or permanent staff, consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK), Officers, Trustees, Board, and/or Committee members at any level. No one is above the law.

In the context of this policy, a third party refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.

Any arrangements our company makes with a third party are subject to clear contractual terms, which should include specific provisions that require the third party to comply with this policy or any like for like policy of their own.

Definition of bribery

So we’re all on the same page, it’s important to lay out what exactly we’re discussing here in clear terms. Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision.

A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.

Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.

Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or an act of hospitality, they must seek further advice from the company’s Chief Operating Officer, or in their absence Chief Executive Officer.

What is and what is NOT acceptable

This section of the policy refers to 4 areas:

  • Gifts and hospitality.
  • Facilitation payments.
  • Political contributions.
  • Charitable contributions.

Gifts and hospitality

Passenger accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements:

  • It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits.
  • It is not made with the suggestion that a return favour is expected.
  • It is in compliance with local law.
  • It is given in the name of the company, not in an individual’s name.
  • It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).
  • It is appropriate for the circumstances (e.g. giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).
  • It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.
  • It is given/received openly, not secretly.
  • It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.
  • It is not above a certain excessive value, as pre-determined by the company’s compliance manager (usually in excess of £100).
  • It is not offered to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s Chief Operating Officer, or in their absence Chief Executive Officer.

Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted so long as it is declared to the Chief Operating Officer, or in their absence Chief Executive Officer, who will assess the circumstances.

Passenger recognises that the practice of giving and receiving business gifts vary between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each.

As good practice, gifts given and received should always be disclosed to the Chief Operating Officer, or in their absence Chief Executive Officer. Gifts from suppliers should always be disclosed.

The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the Chief Operating Officer, or in their absence Chief Executive Officer should be sought.

Facilitation Payments and Kickbacks

Passenger does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action.

We recognise that they tend to be made by low-level officials with the intention of securing or speeding up the performance of a certain duty or action.

Passenger does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage.

Passenger recognises that, despite our strict policy on facilitation payments and kickbacks, employees may face a situation where avoiding a facilitation payment or kickback may put their/their family’s personal security at risk. Under these circumstances, the following steps must be taken:

  • Keep any amount to the minimum.
  • Ask for a receipt, detailing the amount and reason for the payment.
  • Create a record concerning the payment.
  • Report this incident to your line manager.

Political Contributions

Passenger will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage.

Charitable Contributions

Passenger accepts (and indeed encourages) the act of donating to charities – whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes.

Passenger encourages employees to be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery.

We will ensure that all charitable donations made are legal and ethical under local laws and practices and that donations are not offered/made without the approval of the Chief Operating Officer, or in their absence Chief Executive Officer.

Employee Responsibilities

As an employee of Passenger, you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other anti-bribery and corruption information you are given.

All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. You are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy.

If you have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, you must notify Chief Operating Officer, or in their absence Chief Executive Officer.

If any employee is found to have been in breach of this policy, they will face disciplinary action and could face dismissal for gross misconduct.

What happens if I need to raise a concern?

This section of the policy covers 3 areas:

  • How to raise a concern.
  • What to do if you are a victim of bribery or corruption.
  • Protection.

How to raise a concern

If you suspect that there is an instance of bribery or corrupt activities occurring in relation to Passenger, you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain about whether a certain action or behaviour can be considered bribery or corruption, you should speak to your line manager, Chief Operating Officer, or in their absence Chief Executive Officer.

Passenger will familiarise all employees with its whistleblowing procedures so employees can vocalise their concerns swiftly and confidentially.

What to do if you are a victim of bribery or corruption
You must tell your compliance manager as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity.


If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of bribery or corruption, Passenger understands that you may feel worried about potential repercussions. Passenger will support anyone who raises concerns in good faith under this policy, even if an investigation finds that they were mistaken.

Passenger will ensure that no one suffers any detrimental treatment (dismissal, disciplinary action, treats, or unfavourable treatment in relation to the concern the individual raised) as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption.

If you have reason to believe you’ve been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, you should inform your line manager or Chief Operating Officer, or in their absence Chief Executive Officer immediately.

Record keeping

Passenger will keep detailed and accurate financial records and will have appropriate internal controls in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given, and understand that gifts and acts of hospitality are subject to managerial review.