Bribery, fraud and tax evasion
Executive responsibility:
Company Secretary
Link to foundations:
Committed colleagues, committed suppliers
Link to principal risks:
Regulatory and compliance
Our targets:
- 100% of internal training completed.
Our commitment
We are committed to acting legally, fairly, and honestly in all of our business dealings and relationships.
About our approach to bribery, fraud, and tax evasion
We apply our policies across all of our operations, and also require all of our suppliers to commit to apply the same or equivalent policies.
Covid-19 impact and learnings
We reinforced the need for vigilance and adherence to our commitment, and took steps to address additional risk, for example, potential online fraud due to the prevalence of home working. We also put in place new listening groups and a live blog on Home Comforts to enable colleagues to feedback comments on our Covid-19 safety procedures.
Performance against target
INTERNAL TRAINING COMPLETED, % COLLEAGUES
94%
Why this measure is important
- To provide assurance that our colleagues are aware of the legal requirements and can identify wrongdoing by others.
2019/20 performance
- During the year 94% of eligible colleagues completed initial or refresher training; however, we did not meet our target of 100% owing to colleagues being on furlough. Refresher training has been rolled out in July 2020.
What’s next for 2020/21
- Continue with face-to-face and refresher awareness training.
- Review the status of any remaining self-employed contractors in advance of the tax law changes in April 2021.
- Refresh awareness of our whistleblowing/‘Speak Up’ helpline.
Update on activities 2019/20
- Additional training provided to Finance and Logistics teams.
- Externally hosted whistleblowing helpline rebranded as ’Speak Up’ and awareness raised through colleague communications.
- Policy and process for engaging self-employed contractors updated to include analysis of tax risk, audit completed of all self-employed contractors, and many engaged as employees.
Our policies
Anti-corruption, anti-bribery and tax evasion
Dunelm takes a zero-tolerance approach to bribery, corruption, fraud and tax evasion.The Group pays corporation tax on its operations in the United Kingdom and Jersey and does not operate in any tax havens or use any tax avoidance schemes. Our anti-corruption and anti-bribery policy and our Tax Strategy are available in the Group Policies section of the website.
Potential risks to our business
The main areas of potential risk in Dunelm’s organisation are:
- A colleague accepting a bribe or some other personal advantage in return for awarding a contract.
- A supplier acting on Dunelm’s behalf offering or accepting a bribe or other personal advantage.
- A Dunelm colleague facilitating tax evasion by a third party, for example by making an ‘off book’ payment to enable a third party to avoid tax.
Bribery Act 2011
The procedures in place to ensure compliance with the Bribery Act 2011 and other relevant legislation are set out below:
- Anti-corruption and anti-bribery policy implemented – which also covers fraud and tax evasion.
- Formal procedure implemented for signing off and logging gifts and hospitality accepted by colleagues.
- Executive Board members, senior colleagues, all members of the Commercial team and any individuals with authority to place significant contract orders have received anti-bribery training and complete an annual refresher.
- All senior colleagues sign a declaration of compliance and conflicts of interest statement annually.
- Standard terms and conditions for suppliers include a Bribery Act and tax evasion clause.
- Specific training has been carried out for suppliers and agents in high-risk territories.
- All payments to third parties must be supported by a valid invoice and segregated duties are in place in the Finance team; commercial checks made on all new suppliers; policy on engagement of contractors under review.
- Our whistleblowing policy refers specifically to the Bribery Act, fraud and tax evasion and an externally hosted independent helpline is in place.
- Standing agenda item for the Audit and Risk Committee.