Anti-bribery and corruption statement


The Bribery Act 2010 (“the Act”) became effective from 1st July 2011. The Act repeals and consolidates previous corruption legislation.

In addition to the established criminal offences of giving and receiving a bribe, this Act places specific responsibility on organisations to have in place adequate procedures to prevent bribery. Should bribery occur, as well as the offences on the part of the individuals concerned, organisations will also be liable for the corporate offence of failing to prevent bribery unless they can demonstrate that adequate preventative measures were in place.

Bribery occurs where there is intent to give someone a financial or other advantage to encourage that person to perform their functions or activities improperly or to reward that person for having already done so.  It is an inducement for an action which is illegal, unethical, or a breach of trust, and can take the form of gifts, loans, fees, rewards, or other privileges.

CCLA values its reputation and is committed to maintaining the highest level of ethical standards during the course of its business. The acts and conduct of all employees and those working on CCLA’s behalf are fundamental to maintaining those standards.

Corruption is any form of abuse or entrusted power for private gain and will include, but is not limited to, bribery. Bribes are not only just the transfer of monies; gifts, hospitality and entertainment can be bribes it they are intended to influence a decision.


The Act applies to firm’s who do business in the UK (whether incorporated in the UK or not), doing business anywhere in the world.

An offence under Sections 1, 2 and 6 of the Act apply to acts committed overseas (where the act or omission would have been an offence if committed in the UK) and the person has a close connection with the UK. Those with a close connection are defined to include British citizens, a Scottish partnership, individuals ordinarily resident in any part of the UK and bodies incorporated under UK law.

It will be a defence (under section 7 (2)) for a commercial organisation to prove that it had in place adequate procedures designed to prevent persons associated with it undertaking offences under the Act.

All directors and employees are required to comply with this Anti-Bribery Policy.


The Act’s statutory offences are as follows:

Offences of bribing another person “The active offence” (Section 1)

It is an offence to offer, promise or give a financial or other advantage (“bribe”) to another person where it is intended to induce the improper performance of a relevant function or activity or to reward for such an improper performance.

Maximum penalty: 10 years imprisonment and/or unlimited fine.

Offences relating to being bribed “The passive offence” (Section 2)

It is an offence for a person to request, agree to receive or accept a bribe. It does not matter whether the recipient of the bribe receives it directly or through a third party.

Maximum penalty: 10 years imprisonment and/or unlimited fine.

Bribery of foreign public officials (Section 6)

It is an offence to bribe a foreign public official (“FPO”), where it is intended to influence the FPO in the performance of his or her official functions in order to obtain or retain business or an advantage.

Maximum penalty: 10 years imprisonment and/or unlimited fine.

Failure of commercial organisations to prevent bribery (Section 7)

It is an offence for a commercial organisation (including a body corporate, partnerships conducting business in the UK) to fail to prevent bribery by persons performing services on its behalf (“associate persons”). Such an offence will arise where a person associated with the organisation bribes another person intending to obtain or retain business for the organisation or to obtain or retain an advantage in the conduct of business for the organisation. Persons "associated" with the organisation could include employees, agents, contractors and joint-venture arrangements and subsidiaries. However, a subsidiary will only be an associated person if the bribe obtained is intended to benefit the Parent directly.

Penalty: unlimited fine.

Offences under sections 1, 2, and 6 by bodies corporate (Section 14)

A senior officer of a commercial organisation will be personally liable if the offence under section 1, 2 and 6 has been committed with his/her consent or participation, involvement, responsibility or collusion.

Maximum penalty: 10 years imprisonment and/or an unlimited fine.


The Ministry of Justice has issued Guidance that sets out the six principles intended to assist a firm in ensuring that the adequate procedures are proportionate to the nature, scale and complexity of a firm and to assist a firm in complying with the Act. CCLA’s procedures cover these six principles and are as follows:

Top Level Commitment

CCLA is committed to deterring, preventing and detecting bribery in the following ways:

•           There is zero-tolerance towards bribery and such acts would be regarded as gross misconduct or breach of contract. Employees may also face legal action by the Serious Fraud Office (“SFO”) if they act in breach of this Policy (see penalties under the offences outlined above).

•           The giving or receiving of improper inducements, of any value, is strictly prohibited.

•           Facilitation payments must not be made or charged.

•           The nature of each of CCLA’s sponsorship relationships is fully documented in an approved marketing plan. 

•           CCLA does not make financial contributions to favour particular political parties. 

•           Charitable donations are rare and are approved at formal meetings of the Executive Committee.

•           The Executive Directors have taken reasonable steps to ensure that all employees and business partners are aware of this Policy in respect of corruption and that it works along-side existing policies which, in sum, is considered to be the anti-corruption framework of CCLA.


Risk Assessment and Proportionality

A periodic risk assessment will be carried out to ensure procedures are proportionate to the bribery risks that CCLA or its associated persons face, and to the nature, scale and complexity of the business.

CCLA’s risk has been assessed as generally low because it does not operate in a risky business sector and is a relatively small firm.  Most of CCLA’s third party associated persons are UK suppliers of standard goods or services which are considered to represent a very low to zero risk.  Many of these are Financial Conduct Authority (“FCA”) regulated firms. Also, the jurisdiction is mainly UK only, although some investment relationships may present exposure to offshore markets. CCLA’s procedures have been prepared with these risks in mind. These risks are reconsidered on an informal basis at the time for new lines of business and new business relationships.  

Due Diligence

Due diligence is undertaken on all goods and services providers, and includes due diligence on directors, employees, agents and other third parties as determined by our risk assessment.

Communication and Training

CCLA has a zero-tolerance approach to bribery and corruption and this is communicated to all third parties that provide a service to CCLA at the outset of the business relationship.

To enhance awareness and help deter bribery CCLA has the following arrangements in place:

•           All directors and employees of CCLA, together with third parties operating in overseas markets (and possibly others as determined from time to time from our risk assessment and contract approval process) must complete the Anti-Bribery and Corruption e-learning module at onboarding and on an annual basis.

•           CCLA obtains a written acknowledgement to comply with the compliance manual and adherence to other CCLA policies.

•           Any subsequent revision of the Compliance Manual will be circulated to all employees.

•           All contracts include an anti-bribery clause.

•           Other third parties where there is a lower risk of bribery will receive notification of the Anti-bribery Policy with a request to comply.

•           Future associated persons will be treated similarly at the time of appointment.

•           CCLA’s Anti-Bribery Policy is published on its website.

Monitoring & Review

CCLA will monitor and evaluate the effectiveness of its bribery prevention procedures as part of its ongoing review of systems and controls.

A formal update and review of the bribery risk assessment is carried periodically in conjunction with the existing fraud risk assessment process.

Changes to business partners and lines of business are considered in relation to bribery risks, as they occur.

CCLA has a predetermined value of gifts and hospitality, given or received, that must be notified to Line Management for approval and compliance for review. All gifts and hospitality given or received are reported to the Executive Committee on a quarterly basis.

There is a dual control approval process for all company payments which ensures they are for valid purposes.

Raising a Concern

Should employees (or any associated persons) be approached with a bribe or wish to report any concerns or allegations they should report the matter confidentially to the Chief Executive Officer or Chief Risk Officer.

Responsibilities of the MLRO

In relation to reports of bribes or suspicion reports made by an employee the Chief Risk Officer shall be responsible for analysing the basis of these reports. Where a decision has been made not to contact the NCA, a record will be kept internally.

The NCA encourages self-reporting by firms. If you have been a victim of fraud, please call Action Fraud on 0300 123 2040.

CCLA also considers the obligation to report any suspicions to the National Crime Agency (“NCA”). The benefit gained by virtue of a payment of a bribe will be tainted by the act of illegality through which it was obtained and is likely to constitute criminal property under the Proceeds of Crime Act 2002 (“POCA”), the main UK anti-money laundering legislation. Under POCA, criminal property is property that represents a benefit from criminal conduct. A person who did not commit an underlying offence can still commit a money laundering offence where he/she holds property that represents a benefit under that offence. Therefore, it does not matter who engaged in the criminal conduct; where criminal property is generated a money laundering offence will be committed.                                             

CCLA’s MLRO will determine whether, or not, to report the matter to the NCA.

December 2020




Terms and conditions

Website terms of use policy

CCLA Website Terms of Use

Welcome to CCLA's website for:

  • fund management services for  CCLA Funds (details of and documentation relating to all CCLA Funds is available on CCLA’s website); and
  • discretionary investment management services for individual client portfolios.

This page provides you with information about CCLA and the legal terms and conditions (Terms of Use or Terms) on which you can access and use this website.

By using or accessing any part of this website, you confirm that you accept these Terms of Use and that you agree to comply with them.  Please read these Terms of Use carefully and make sure that you understand them before using this website. If you do not wish to be bound by these Terms you must not use or access this website.

Where necessary, we may amend these Terms of Use from time to time by updating this page.  We therefore recommend that you check this page periodically to ensure that you understand the Terms which will apply from time to time.

1. About us (CCLA)

1.1 Any reference to CCLA or we/us on this website (including these Terms of Use) means CCLA Investment Management Limited and/or CCLA Fund Managers Limited (as applicable).

1.2 CCLA Investment Management Limited (CCLA IM) is a company registered in England and Wales with company number 2183088. It is authorised and regulated by the Financial Conduct Authority under the Financial Services and Markets Act 2000 (FSMA), and is entered on the Financial Services Register under registration number 119281.

1.3 CCLA Fund Managers Limited (CCLA FM) is a company registered in England and Wales with company number 8735639.It is authorised and regulated by the Financial Conduct Authority under FSMA and is entered on the Financial Services Register under registration number 611707.

1.4  The registered office of CCLA IM and CCLA FM is Senator House, 85 Queen Victoria Street, London, EC4V 4ET.You may also contact CCLA by emailing

2. Who may use this website

2.1 The information on this website is intended for investors and prospective investors in the CCLA Funds and or clients or prospective clients of CCLA's services. Only certain types of investor are eligible to invest in the CCLA Funds (in summary these are charities and local authorities and certain of the CCLA Funds are restricted to particular types of these investors).

  • Charities for these purposes are charities or charitable organisations registered with the Charity Commission of England and Wales, or charities exempt from registration, or other persons eligible to participate in collective investment schemes constituted under the Church Funds Investment Measure 1958, section 24 of the Charities Act 1993 (now amended to section 96 of the Charities Act 2011), or section 25 of the Charities Act 1993 (now amended to 100 of the Charities Act 2011), or equivalent organisations in Scotland or Northern Ireland.
  • Local authorities for these purposes are local authorities as defined in section 23 of the Local Government Act 2003.

2.2 Please ensure that you understand whether or not you are an eligible investor in respect of the CCLA Funds, investments and investment services referred to on this website.

3. The purpose of this website

3.1 This website is for information purposes only and is intended as a general introduction to CCLA and the Funds it manages and/or provides investment management services to. The website content and any products and/or services described within it are subject to change without notice.

3.2 Nothing contained on this website constitutes the provision of investment, tax, legal or other advice. This website should not be regarded as constituting a distribution or an offer or solicitation to sell shares or units in any of the funds managed by CCLA outside the UK. Any opinions expressed on individual funds, services or products represent our views at the time of preparation and should not be interpreted as a personal recommendation to buy or sell any of the investments that may be referred to.

3.3 In using this website you may navigate between different pages which relate to different Funds. Each webpage will clearly identify the Fund to which it relates and bespoke information presented on each webpage will relate to the identified Fund.

4. Risk warning

4.1 The value of the CCLA Funds’ units and/or shares and the income from them can fall as well as rise and an investor may not get back the amount originally invested. Past performance is no guarantee of future returns.

4.2 Please refer to the Funds’ individual scheme particulars or prospectus for an overview of the investment risks identified by CCLA and the applicable terms and conditions for investing in the Funds, including rules concerning when sums invested may be realised by the investor. Any estimates of future capital or income returns or details of past performance on this website are for information purposes and are not to be relied on as a guide to future performance.

4.3 Persons who do not have professional experience in matters relating to investments are strongly encouraged to consult with a financial adviser before making any investment decision.

5. Complaints and compensation

8.1  All complaints will be handled in accordance with CCLA’s Complaints Policy  which can be found at

 If either CCLA IM or CCLA FM cannot meet its obligations (for example, where it has stopped trading and there are insufficient assets to meet its obligations), investors may be eligible to claim compensation up to a maximum of £85,000 from the Financial Services Compensation Scheme. There are limits on who is eligible to claim and which funds are covered. For further information about the Financial Services Compensation Scheme please refer to or phone 0800 678 1100.

6. CCLA's liability

6.1 We give no warranty or representation and accept no liability for the accuracy, completeness or appropriateness of the information and material available on this website. Your use of any information or materials is entirely at your own risk and we accept no liability for any damage or loss including loss of profit whether direct, indirect or consequential in respect of the use of this website or its content; however, we do not exclude or restrict any liability that we may have under FSMA.

6.2 Due to the nature of the Internet, errors, interruptions and delays may occur at any time. Accordingly, this website is provided on an "AS IS" and "AS AVAILABLE" basis without any warranties of any kind. We shall have no liability, contingent or otherwise, or any responsibility whatsoever, for any interruption in availability of this website regardless of whether the connection or communication service is provided by CCLA or a third party service provider.

6.3 Transmission of information via the Internet is not completely secure and we cannot guarantee the security of your data transmitted to this website. Any transmission is at your own risk. We will use strict procedures and security features to try to prevent unauthorised access and we will do our best to protect your information (including personal data). However, we accept no liability in the unlikely event of a breach of our secure computer servers.

6.4 We will use reasonable endeavours to ensure that this website does not contain or promulgate any viruses or other malicious code. However, it is recommended that you should virus check all materials downloaded from this website. We will not be liable for any viruses, code, files or programs designed to interrupt, restrict, destroy or otherwise compromise the integrity of the website or any hardware on which it is hosted. We exclude to the fullest extent permitted by applicable laws all liability in connection with any damage or loss caused by computer viruses or other malicious code originating or contracted from this website.

7. Third party websites

7.1 This website may provide links to certain websites sponsored and maintained by third parties. CCLA is not responsible for the accuracy of information contained within websites provided by third parties and makes no representations concerning the content of such third party websites. The fact that CCLA may provide a link to another website does not constitute an endorsement, authorisation, sponsorship, or affiliation by CCLA with respect to that website, its owners, or its providers. You will be responsible for complying with the terms and conditions of use for any linked website.

8. Copyright and trade marks

8.1 CCLA is the owner or the licensee of all intellectual property rights in this website, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.

8.2 You must not use any part of the materials on this website for commercial purposes without obtaining a licence to do so from us or our licensors.

8.3 No use of CCLA's name, logos and/or other trademarks (whether registered or unregistered) may be made by you without separate express written agreement being given by us, which shall be at our sole discretion.

9. Data protection

9.1 We will hold any personal information that you may provide to us through our CCLA website in confidence and in accordance with CCLA’s Privacy Notice and current Data Protection Legislation. CCLA is the data controller of any such information for these purposes.

9.2 You agree that the CCLA may process your personal data to: (i) confirm your identity and carry out background checks (which may involve sharing your personal data with third parties such as credit reference agencies); (ii) provide our services to you; (iii) follow up with you after you request information; (iv) comply with any requirement of any applicable statute, regulation, Financial Conduct Authority Rule and good practice and to fulfil our obligations under any reporting agreement entered into with any tax authority or revenue service(s); (v) prevent and detect abuse of our services or any of our rights and to protect our (and others’) property and rights; (vi) contact you by post, e-mail or telephone to bring to your attention additional products or services which may be of interest to you (you may inform CCLA at any time if you do not want to receive such communications); and (vii) as otherwise agreed by you. Failure to provide the personal data requested (or to agree to the above or below uses) may mean that CCLA is unable to provide the services requested.

9.3 CCLA may pass your personal data to any other firm within CCLA but will not pass on any personal data to any other third party except: (i) where, in relation to the performance of its services to you, CCLA sub-contracts part of the services or any support services; (ii) as agreed by you; or (iii) where required to do so for regulatory purposes as set out above.

9.4 CCLA may in exceptional circumstances transmit and process your personal data outside of the UK  in countries that do not provide the same level of data protection as the UK. In such unusual circumstances, you agree that it may do so subject to CCLA endeavouring to ensure that the arrangements comply with the standards required by the UK Information Commissioner.

9.5 Your use of this website (and your interest in particular webpages or particular CCLA products or services) may be monitored by CCLA. CCLA may keep records of all business transactions for at least five years.

9.6 By accepting these Terms of Use, you agree to the processing and disclosure of personal information as above. You are entitled to request details of information we may hold about you and to require us to correct any inaccuracies in your personal data. CCLA will treat all clients' records as confidential and so reserve the right to provide copies of your particular record, rather than allow access to files which may contain information about other clients. If you wish to access copies of your personal data or ask about the above arrangements, please contact CCLA's Data Protection Adviser at CCLA Investment Management Limited, Senator House, 85 Queen Victoria Street, London, EC4V 4ET.

9.7 Full details of CCLA’s Privacy Notice is available on CCLA’s website. Full details of CCLA’s Data Protection Policy, are available on request.

10. Cookies

10.1 This website uses cookies to distinguish you from other users of the website. This helps us to provide you with a good experience when you browse the website and also allows us to improve the website.

10.2 When you confirm you have read this page we will place a cookie on your computer to recognise you and prevent this page reappearing should you access this website on future occasions. The cookie will expire after six months, or sooner should there be a change to this important information.

10.3 You can activate the setting on your Internet browser to refuse the setting of all or some cookies. However, if you use your Internet browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the website. To help us provide a more personalised viewing experience we recommend that you view this website with a JavaScript enabled browser.

10.4 For more information about cookies, including how to set your Internet browser to reject cookies, please visit

11. Recording of communications

 Your telephone calls and electronic communications with CCLA may be recorded. You agree that CCLA may deliver copies or transcripts of such recording to any court or competent regulatory authority.  Such records of conversation and/or communications with you will be available on request for a period of five years (or, where requested by the FCA, for a period of up to seven years) from the date when a record is made.

12. General

12.1 Each of the paragraphs of these Terms of Use operates separately. If any court or relevant authority decides that any of them are unlawful or unenforceable, the remaining paragraphs will remain in full force and effect.

12.2 If we fail to insist that you perform any of your obligations under these Terms of Use, or if we do not enforce our rights against you, or if we delay in doing so, that will not mean that we have waived our rights against you and will not mean that you do not have to comply with those obligations.

12.3 These Terms of Use are governed by English law and are available only in English. You and we both agree that the courts of England and Wales will have non-exclusive jurisdiction over any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with these Terms of Use.

18 August 2021             




Public sector funds

Public sector funds

The Local Authorities Property Fund (“LAPF” or “the fund”) is an unregulated collective investment scheme. As such, only persons who have been assessed as elective professional clients by CCLA in respect of the fund (or are already investors in the fund) are able to access details of the fund on this website.

If you have not been assessed as an elective professional client by CCLA or are not an existing investor in the fund, please contact us to discuss this fund:

Client Services

0800 022 3505

I confirm that I am a local authority/public sector body as defined in section 23 of the Local Government Act 2003. I also confirm that I have been assessed as an elective professional client by CCLA and/or I am an existing investor in the LAPF.