1. Introduction

The College has a zero-tolerance for bribery and corruption. The College’s reputation with the community it serves and other stakeholders is underpinned by ethical behaviour, financial probity and honesty. The College aims to limit its exposure to bribery by:
  •  Setting out a clear anti-bribery policy, which is proportionate to the risks that the College is exposed to;
  •  Embedding awareness and understanding of the College’s anti-bribery policy amongst all staff, “associated persons” (any person performing services for or on behalf of the College), and external persons/organisations with whom the College has commercial relations;
  • Training staff as appropriate so that they can recognise and avoid the use of bribery by themselves and others;
  • Encouraging staff to be vigilant and to report any suspicion of bribery, providing them with suitable channels of communication and ensuring sensitive information is treated appropriately;
  • Rigorously investigating instances of alleged bribery in accordance with the College disciplinary procedure; and assisting the Police and other appropriate authorities in any resultant prosecution;
  •  Taking firm and vigorous action against any individual(s) involved in bribery.

2.                  The Policy

This policy applies to all employees and anyone acting for, or on behalf of, the College (“associated persons”), including governors, other volunteers, temporary workers, consultants and contractors.
All employees and associated persons are responsible for maintaining the highest standards of business conduct and are expected to behave honestly and with integrity. Any breach of this policy will constitute a serious disciplinary offence, which may lead to dismissal and may become a criminal matter for the individual.
The College prohibits employees and associated persons from offering, giving, soliciting or accepting any bribe. The bribe might include cash, a gift or other inducement, to or from any persons or organisation, wherever they are situated, and irrespective of whether or not they are a public official/body or private person or company, by any individual governor, employee, agent or other person or body acting on the College’s behalf. The bribe might be made in order to:
  • Gain any commercial, contractual or regulatory advantage for the College in a way which is unethical;
  • Gain any personal advantage, pecuniary, or otherwise, for the individual or anyone connected with the individual.
This policy is not intended to prohibit appropriate corporate entertainment and/or hospitality undertaken in connection with the College’s business activities, provided the activity is customary under the circumstances, is proportionate, and is the properly recorded/disclosed to the College in accordance with its procedures.
Employees and associated persons are requested to remain vigilant in preventing, detecting and reporting bribery. Employees and associated persons are expected to report any concerns regarding any suspected bribery.