Anti-Bribery and Anti-Corruption Policy

Policy statement #

The mission of Rust Foundation (the “Foundation”) is to support the maintenance and development of the open source Rust programming language and related projects. The Foundation is committed to conducting its business in an honest and ethical manner. We commit to:

  • preventing bribery and corruption in our business
  • acting professionally, fairly and with integrity in all of our external relationships
  • making all of our participants aware of, and holding them to, their responsibilities under this policy
  • upholding all laws relating to anti-corruption and bribery, in all the jurisdictions in which we operate

The purpose of this policy is to set out our responsibilities, and the responsibilities of those working for us, in upholding our position on corruption and bribery; and to provide information and guidance for our participants on how to recognise and deal with corruption and bribery issues.

This Policy applies to all participants in Foundation-related activities, including Foundation employees, consultants, directors, officers, members, and volunteers (together, “participants”). As a participant, 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. For employees of the Foundation, breaches of this policy will lead to disciplinary action.

Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, joint venturers, contractors and business partners.

Definitions #

Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so as to induce or influence an action or decision.

Corruption refers to dishonest behavior by those in positions of power. Bribery is just one example of corruption. There are many situations in which a person may be considered corrupt.

If you’re uncertain about whether something can be considered bribery or corruption, you should speak to the Executive Director. If you’re unwilling to speak to the Executive Director (most obviously this will be the case when it is the Executive Director’s conduct that is under question) then you should speak to the chair of the board.

What is and is not acceptable? #

It is not acceptable for the Rust Foundation, its participants, or someone acting on its behalf to:

  • Give, promise to give, or offer, any payment, gift or hospitality in the expectation or hope of receiving a business advantage or a return favour, or to reward one already given
  • Accept any payment, gift or hospitality from a third party if you know or suspect it is offered with the expectation or hope of us providing a business advantage to them or assisting them to obtain a business advantage, or is offered as a reward for a business advantage they perceive to have already received
  • Give, promise to give, or offer, any payment, gift or hospitality to anyone which would cause them to be in breach of their own obligations, such as a policy preventing them from accepting such
  • Threaten or retaliate against another worker who has refused to commit a bribery offence, or who has raised concerns under this policy
  • Engage in any other activity that might lead to a breach of this policy

It is also not acceptable to make any form of facilitation payment, defined as a payment made to expedite or facilitate the performance of a public official for a routine governmental action. However, we recognise that these are common in some jurisdictions, hence participants may face a situation where not doing so may put their personal safety at risk. Under this circumstance they must keep any amount to the minimum, ask for a receipt, and report the incident to the Executive Director.

It is acceptable to give or receive normal and appropriate gestures of hospitality and goodwill from third parties, provided that:

  • It is not made with the intention of influencing the recipient, to obtain a business advantage or a return favour, or to reward one
  • It does not include cash or cash equivalents such as a gift voucher
  • The gift is made in the name of the company, not an individual
  • It happens openly, not secretly
  • It is of an appropriate nature and value for the occasion
  • It is in compliance with local law

We recognise that the practice of giving and receiving business gifts varies between countries and cultures, and that there are circumstances in which it may be inappropriate to decline the offer of a gift lest it should cause offence. Gifts given and received should always be disclosed to the Executive Director.

The Rust Foundation supports the act of donating to charities, whilst recognising that there is a risk of charitable donations being used to facilitate and conceal acts of bribery. We will ensure that all charitable donations made are legal and ethical, and will disclose all charitable contributions we make.

We will undertake due diligence on our grant recipients, and take reasonable steps to ensure they are aware of this policy and comply with all applicable anti-bribery and anti-corruption laws.

As a 501(c)6 organization, we are not prohibited from lobbying and making donations (whether in cash, kind, or by any other means) to support political parties or candidates, but these are not activities in which we currently engage.

We will keep a written record of all donations, hospitality or gifts accepted or offered, which will evidence the circumstances and business reason for each instance.

How to raise a concern #

Participants who refuse to engage in bribery, or who raise concerns, are sometimes worried about possible repercussions. We want to assure our participants that we encourage openness and will support anyone who raises genuine concerns in good faith, and ensure they do not suffer any detrimental treatment as a result.

You can contact the Foundation regarding matters addressed by this Policy. Please reference “Foundation Anti-Bribery and Anti-Corruption Policy” in the subject line.

To the fullest extent possible, your report will be treated as confidential and we will let you know the outcome of the enquiry into your suspicions.