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D. Implementation

  1. Responsibility for implementation of this policy lies with the Audit Committee, supported by the Registrary.
  2. The commitment by the University to preventing bribery and fraud shall be clearly and regularly communicated to staff and associated persons through processes to be instituted by the Registrary.
  3. The nature and extent of the risks relating to bribery and fraud to which the University is exposed shall be assessed by the Audit Committee at least annually and appropriate changes to this or other policies shall be implemented to reflect the outcomes of such risk assessments.
  4. Staff and associated persons are encouraged to undertake risk assessments where they consider that there is a risk that bribery and/or fraud might occur in relation to a particular transaction, third party or territory and to undertake appropriate due diligence prior to proceeding.
  5. This Policy shall be available to every member of staff and the University shall arrange specific training for those deemed most likely to encounter bribery and fraud. The University's prohibition of bribery and fraud shall be communicated to all suppliers, contractors and business partners at the outset of any business relationship with them and as appropriate thereafter.
  6. The University's procedures to prevent bribery and fraud through this and other policies shall be monitored and reviewed by the Audit Committee at least every three years to assess their suitability, adequacy and effectiveness. This Policy may be amended from time to time to reflect legal requirements or best practice recommendations and in the light of any instances of bribery and fraud.