Anti-Bribery and Corruption Policy

ATTP operates with absolute zero tolerance for bribery and corruption in any form. This applies to every individual acting on behalf of ATTP: the Founder, staff, volunteers, contractors, trustees, and anyone else representing the organisation. This policy is grounded in the principles of the UK Bribery Act 2010, the Independent Corrupt Practices and Other Related Offences Act (ICPC Act) 2000 of Nigeria, the United States Foreign Corrupt Practices Act 1977 (FCPA), and the Transparency International Business Principles for Countering Bribery.

ATTP's mission to serve young people in Nigeria depends on the integrity of its people and the trust of its funders, partners, schools, and communities. Corruption destroys both.

This policy applies to:

(a) All staff, trustees, and volunteers of ATTP, regardless of location. (b) All contractors, consultants, and agents acting on ATTP's behalf. (c) All activities conducted by ATTP or on its behalf, whether in Nigeria or elsewhere.

No person acting on behalf of ATTP may:

(a) Offer, promise, give, request, or accept any bribe: a financial or non-financial advantage intended to induce or reward improper performance of a function or activity, or to gain a business, official, or personal advantage. (b) Pay or accept kickbacks: undisclosed commissions or payments in connection with ATTP contracts or transactions. (c) Make facilitation payments: unofficial payments made to government officials or others to speed up or secure a routine action to which ATTP is legally entitled. These are bribes, regardless of their size or local custom. (d) Use a third party to offer or accept a bribe on ATTP's behalf. (e) Misrepresent ATTP's activities, finances, or outcomes to funders, regulators, or partners for the purpose of obtaining funding, approvals, or other benefits.

ATTP recognises that reasonable gifts and hospitality can form part of normal professional and community relationships. However:

(a) No gift or hospitality with a value exceeding NGN 10,000 (or equivalent) may be accepted without prior approval from the Founder. (b) No gift or hospitality of any value may be accepted if it is offered in connection with a decision ATTP is about to make, a contract ATTP is awarding, or any situation where a conflict of interest might arise. (c) All gifts and hospitality above NGN 5,000 in value, whether offered or received, must be recorded in the Conflicts Register at attpglobal.com/admin/governance. (d) Gifts of cash or cash equivalents (vouchers, gift cards) may never be accepted or offered. (e) Hospitality offered by ATTP to partners, funders, or guests must be reasonable, proportionate, and approved in advance.

ATTP will not make donations, in cash or in kind, to any political party, candidate, or campaign, whether in Nigeria or elsewhere. Sponsorship of politically affiliated events is also prohibited.

Any individual with knowledge or reasonable suspicion of a bribery or corruption concern relating to ATTP must report it as soon as possible. Reports may be made:

(a) To the Founder directly, where the concern does not involve the Founder. (b) Via the Speak-Up form at attpglobal.com/speak-up, which allows for confidential or anonymous reporting. (c) To a trustee or member of any advisory body, where the concern involves the Founder.

ATTP will not penalise, dismiss, or treat unfairly any individual who raises a genuine bribery or corruption concern in good faith, even if the concern turns out to be unfounded. Retaliation against a reporter is itself a breach of this policy.

Any individual found to have breached this policy will face immediate suspension and, following investigation, likely termination of their engagement with ATTP. ATTP will report credible instances of bribery or corruption to the Independent Corrupt Practices and Other Related Offences Commission (ICPC) and any other relevant authority, and will cooperate fully with any resulting investigation.

All gifts and hospitality above the threshold stated in section 4 will be recorded in the Conflicts Register. ATTP will maintain records of its anti-bribery procedures, training completion, and any concerns raised and investigated, for a minimum of seven years.

All staff and long-term volunteers will receive briefing on this policy at the start of their engagement and will be required to sign a declaration confirming they understand and will comply with it. The policy will be reviewed annually.