Policy against bribery and corruption: Section E

E. Key Roles and Responsibilities

Registrary

19. The Registrary is responsible for ensuring that this Policy is maintained and that appropriate explanatory guidance is provided and for monitoring compliance with the Policy.
20. The Registrary shall have the following specific responsibilities:
    1. to maintain a register of the incidents of Bribery and Fraud that are reported to him or her in accordance with this Policy;
    2. to compile an annual report for the Audit Committee on the implementation of this Policy including the outcomes of any relevant risk assessments and due diligence and any incidents of reported Bribery and Fraud, thereby contributing to the monitoring and review of this Policy; and to recommend any changes to this Policy which, may from time to time, become appropriate;
    3. to ensure that any standard University documents and procedures (including procurement terms and procedures, fundraising documentation, and terms and conditions of employment) reflect the requirements of this Policy;
    4. to coordinate the University's response to any investigation or charge under anti-bribery or fraud legislation;
    5. to ensure that procedures are in place to communicate the Policy to all Staff and any relevant Associated Persons and to deliver appropriate training to Staff;
    6. to oversee the compilation of specific Bribery and Fraud risk assessments and the conduct of appropriate due diligence into significant areas of activity with a view to assessing Bribery and Fraud risks and taking appropriate action to mitigate them.
    7. The Registrary may delegate these responsibilities to named individuals as he or she sees fit.

Heads of Institution

21. Heads of Institutions are responsible for ensuring Staff complete online anti-bribery, corruption and fraud training. Staff should re-take the training every two years. New staff should complete the training in their first few months. Third parties must confirm in their contracts with the University that they have undertaken their own, equivalent, training.
22. The Audit Committee recommends that Heads of Institutions make the training course mandatory for Staff designated at higher risk of exposure to bribery and fraud, namely staff who:
    1. hold any kind of management role (e.g. all principal investigators) and/or have the authority to incur any level of expenditure;
    2. have international dealings of any kind, but particularly in emerging markets or areas of the world where risk of corruption is higher;
    3. work with contractors;
    4. contract on behalf of CUTS;
    5. are involved at any level in a decision to contract, i.e. to offer or receive goods, services, donations or research grants or contracts;
    6. are involved in procurement at any level.

Staff and Associated Persons

23. Staff and Associated Persons are encouraged to conduct due diligence 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.
24. This Policy shall be available to every member of Staff. The University encourages all Staff to complete training on anti-bribery, corruption and fraud, and specifically requires that the training is completed by all members of Staff who are deemed to be 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.

Audit Committee

25. The nature and extend of the risks relating to Bribery and Fraud to which the University is exposed shall be assessed by the Audit Committee at least once every two years and appropriate changes to this or other policies should be implemented to reflect the outcomes of such risk assessments. The Audit Committee will receive an annual report on compliance with the Policy through the University's assurance framework.

Council

26. The Council is responsible for ensuring that the University has appropriate arrangements in place to prevent Bribery, Corruption and Fraud. 
27. The Council shall review this policy at least every three years and earlier subject to any changes in the Bribery Act 2010 legislation, the Economic Crime and Corporate Transparency Act 2023 and respective guidance.