Policy against bribery and corruption: Annex 2

Annex 2 - Specific guidance

The University has policies and procedures which include provisions to combat fraudulent or corrupt practices with which employees are expected to comply with for all aspects of University business. There are also specific areas where it is considered advisable to provide more specific guidance.

a) The Financial Regulations

The Financial Regulations not only govern in detail the required financial practice within the University, but establish ethical considerations for the conduct of all University business and clarify individual responsibility. In addition, the Financial Procedures Manual provides greater detail on day to day administration of University finances and clarity in certain areas such as business and staff entertainment, research funding and income and procurement of goods and services.

b) Donations

The University does not make political donations, and only makes and receives charitable donations in accordance with the Financial Regulations of the University. Any charitable donations received by the University must be requested and received for exclusively charitable purposes and shall not Improperly influence any decisions made by or on behalf of the University. Acceptance of donations must be made in accordance with the Ethical Guidelines for the Acceptance of Benefactions within the University. See University Statutes and Ordinances: Chapter XIII Finance and Property, Notices by the Council.

c) Hospitality and Entertainment

Excessive or lavish gifts or hospitality in relation to business transactions or arrangements with donors might constitute Bribery.

Acceptance of gifts or hospitality

No University employee or Associated Person may receive gifts or hospitality in connection with University business otherwise than in accordance with and subject to the limits contained in Regulation 2 of the Financial Regulations.

No gift or hospitality should be accepted from a third party where there is or could be any expectation that it will lead to a business advantage for them whether or not provided directly by the University.

Provision of gifts and hospitality

Where a gift or hospitality is being provided by or on behalf of the University

  • It must not exceed normal business courtesy.
  • It must not be made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
  • It must comply with local law(s);
  • It should be given in the name of the University and not in an individual's name;
  • It should be appropriate in the circumstances, of an appropriate type and value and given at an appropriate time;
  • It should be given openly, not secretly;
  • Gifts should not be offered to, or accepted from, government officials or representatives, or politicians or political parties, without the prior approval of the Registrary.

d) Facilitation Payments and Kickbacks

The University will not make any unlawful facilitation payments. Facilitation payments are payments intended to secure or expedite routine or necessary Government action by a Public Official. A facilitation payment includes a payment to a Public Official to do their job properly as well as payment to do their job improperly.