Policy against bribery and corruption: Section B

B. Policy Statement

  1. The University will take appropriate action to prevent Bribery and all forms of Fraud in the University.
  2. No member of Staff or Associated Person shall seek a financial or other advantage for the University through Bribery.
  3. No member of Staff or Associated Person shall offer, promise, give, request, agree to receive or accept a bribe for any purpose.
  4. The University prohibits any form of Fraud within its operations, and no University Staff or Associated Persons may engage in any form of fraud with regard to activity carried out within or on behalf of the University.
  5. University Staff who suspect that Bribery or Fraud has occurred are required to report such instances to the Registrary and the Director of Finance in accordance with Annex 1. The matter will be appropriately investigated, recorded, and reported in accordance with the Financial Regulations and/or the Whistle-blowing procedures. Not withstanding the provisions of Regulation 20 of the Financial Regulations, the Registrary shall be responsible under this Policy for monitoring and recording instances of bribery or fraud and reporting to the Audit Committee in accordance with Section E.
  6. The University undertakes risk assessments to assess the nature and extent of its exposure to potential risk of Bribery and Fraud on behalf of its employees, agents and other associated persons and to identify any new risks. As fraud risks may increase during emergencies, the assessment for fraud risk encompasses a risk assessment for relevant potential emergency scenarios. Emergencies refer to events that pose a risk of widespread loss of life or damage to property, or significant financial instability, and that require ameliorating action by the authorities. Risk assessments are subject to review at least once every two years, or earlier if required. 
  7. The University monitors and reviews its Bribery and Fraud detection and prevention procedures in accordance with the roles and responsibilities as set out in Section E of this Policy.
  8. Bribery and Fraud by Staff will be treated as a serious disciplinary offence resulting, potentially, in dismissal and legal action.

  9. Annex 2 contains more detailed guidance in relation to the Financial Regulations and areas of activity where it is considered that the risk of Bribery and Fraud is particularly high, namely:

    15.1. Donations;

    15.2. Hospitality and Entertainment;

    15.3. Facilitation payments.