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All staff have a responsibility to ensure that neither their conduct, nor the conduct of any person or organisation entering into any contract or arrangement with the University contravenes the Bribery Act 2010. Staff must not use their authority or office for personal gain and must always seek to uphold the reputation and good standing of the University. See the University’s Policy against Bribery and Corruption.

Where instances of bribery are found in organisations, the behaviour of senior management is being subjected to as much scrutiny as that of the perpetrators. Leaders within organisations are seen as personally responsible for ensuring that a culture is fostered where bribery is not tolerated. A failure to do so may lead to prosecution of that institution itself for failure to prevent bribery and in extreme cases to prosecution of senior managers themselves.

Application

The policy applies to all staff and “staff” are defined as all individuals working within the University at all levels and grades, including officers, employees (whether permanent, fixed term or temporary), workers, trainees, seconded staff, agency staff, volunteers, interns or any other person working in any context within the institution. The University could also be liable for the actions of others therefore:

  • the University’s prohibition of bribery and fraud should also be communicated to all suppliers, contractors and business partners at the outset of any business relationship with them and as appropriate thereafter; and
  • compliance with the University’s anti-bribery policy should be included within terms and conditions agreed

Implementation and training requirements

Heads of Institutions are responsible for assessing the risk of any activities to exposure or vulnerability to corruption and ensuring that all staff are aware of the scope and reach of the Act. In particular this includes those involved at any level in procurement, seeking donations, research funding, or those involved in international activities. The simplest and most effective way of doing this is to require their staff to undertake the short on-line Anti-Bribery and Corruption training course which guides individuals through the scope of the Act and highlights some of the situations to be aware of.

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