Following the introduction of the Bribery Act 2010 the University introduced an Anti-Bribery Policy in November 2011. The Policy is available online in PDF format.
Contravention of the Bribery Act can have serious consequences for individuals and the institution – in the most severe instances individuals found guilty of a bribery offence can face fines or prison sentences of up to ten years, and the University may face unlimited fines if it is found to have failed to prevent bribery activity. Any member of staff found to be involved in bribery activity would also be subject to disciplinary procedures. In order to protect the University and its staff we therefore want to ensure that our bribery prevention policies and procedures are embedded and understood, and I am therefore reminding all staff of the policy – please take the trouble to read it if you have not already done so.
In addition to the policy, the University, in conjunction with Marshall ACM, developed an online training package which in less than one hour provides a basic understanding of the key principles of the Bribery Act, and its implications for the University. All staff are encouraged to undertake this training module, which is mandatory for all those whose work means they are at an increased risk of encountering bribery activity. Following feedback from users of the training module, a new upgraded version has been launched, with the aim of providing a more user-friendly experience.
I would also like to remind all staff of the following:
- The University has 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.
- 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 (hospitality which is an integral part of a conference or other similar event that is directly work-related in content is, however, excluded). No gift should be accepted if it 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. Staff travelling to such countries will additionally be required to undertake the module above.
- 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. This Policy can also be used to report concerns anyone may have relating to fraud or other illegal, unethical or dangerous conduct.
Mark Humphriss
University Secretary