Following the introduction of the Bribery Act 2010, which came into force on 1 July 2011, the University has developed an Anti-Bribery Policy, which was recently approved by Council.
The Policy is available online in PDF format.
Under the Bribery Act, the University and its staff could face prosecution and severe penalties if convicted of bribery, as well as endangering the University’s reputation. The Act applies to all our activities, including those which take place overseas. The definition of bribery is broad and includes facilitation payments.
We have, therefore, adopted a zero-tolerance approach to bribery and corruption; it is not acceptable for any member of the University to engage in bribery (whether giving or receiving), or otherwise engage in any activity that might lead to a breach of the Anti-Bribery Policy.
In addition, staff should report any concerns they may have regarding bribery activity of which they become aware.
The policy applies to all staff and students.
We want to ensure that our bribery prevention policies and procedures are embedded and understood; please, therefore, take the trouble to read the Policy. An e-training module is currently being commissioned and should be available in January.
Members of staff are reminded that:
- Any gift or hospitality or services received (or series of gifts within a three month period) with a total value in excess of £50 should be recorded in their department’s register of gifts and hospitality. No gifts should be accepted if they might amount to bribery.
- Some countries present a heightened risk of bribery, and staff travelling abroad should therefore be particularly vigilant and prepared to identify and resist bribery. The Transparency International Corruption Perceptions Index must be used by staff to assess the perceived risks of bribery activity associated with a particular part of the world when travelling outside Europe.
- Any person who has reason to believe that an irregularity with financial implications for the University has or is about to take place, is required to inform their Head of Department and the Head of Internal Audit. If a person feels they are not able to report their concerns directly, they should still consider reporting them by means of the University’s Public Interest Disclosure (Whistleblowing) Policy.