Anti-Bribery & Corruption Policy


The Cumberland Building Society (and its subsidiary Borderway Finance Ltd) has no appetite for a breach of financial crime legislation and will maintain a robust financial crime control environment to protect our customers, meet legislation and comply with the expectations of our regulatory bodies. In this respect, the Cumberland has a zero-tolerance approach to bribery and is committed to preventing bribery and corruption in its activities.

In line with the Bribery Act, the Cumberland, and all those who work here, are committed to acting professionally, fairly and with integrity.

Our Policy

As such, in our policy it is prohibited for employees, agents, third parties, consultants and suppliers who we work with:

  • To bribe another person
  • To accept a bribe
  • To bribe a foreign official

As an organisation we must also:

  • Prevent bribery as a corporate organisation

A bribe is an inducement or reward in return for a commercial, contractual, regulatory, or personal advantage, usually including a financial value. Bribery is offering, promising, or giving a reward or something of value for a business advantage, financial or otherwise or to ask for or accept a reward, or something of value, in return for providing a business advantage to someone, financial or otherwise.

Employees must:

  • Register gifts, entertainment, and hospitality including the receipt or offer of gifts, meals, invitations to events and functions in connection with matters related to Cumberland business;
  • Complete Anti-Bribery training on at least an annual basis;
  • Declare any conflict of interests.

Cumberland must confirm compliance with the Bribery Act through:

  • Completion of a review of the Gift and Hospitality register on at least an annual basis;
  • Completion of an annual bribery and corruption risk assessment;
  • Due diligence of any third parties with whom we do business, to ensure that they also have policies and procedures in place to prevent bribery and corruption.

Reporting Concerns

Employees can report any concerns locally, via the Whistleblowing champion, or externally through the FCA website.