College Deans and Director of Professional Services should review the functions for which their College/Service is responsible and undertake a risk assessment of areas which may be at risk of bribery or other improper conduct and prepare appropriate action plans to mitigate or eliminate these risks.
Risk assessments and action plans should be reviewed at regular intervals, in particular if there is a significant change in the operation of an activity where bribery is a risk (for example, operating in a country for the first time) or if a new activity where bribery is a significant risk is introduced.
Documentation relating to risk assessments and action plans should be retained by the College/Service and made available for internal audit. The documentation may also be required in the event of an investigation under Section 7 of the Bribery Act. A well documented risk assessment and mitigation action plan, together with evidence of its effective implementation, would be essential for the University to demonstrate that it had adequate procedures to prevent bribery.
Actions to eliminate and mitigate risk
Colleges/Services should, through the induction process, ensure that all new staff are aware of the University’s standards and expectations by ensuring that they read and understand the Code of Conduct.
In addition, Colleges/Services should consider the following actions to prevent bribery and other improper conduct by staff. The actions to be implemented should be relevant and proportionate to the risk.
- communication of the University’s standards and procedures (including the Code of Conduct) to staff and other individuals covered by the Code of Conduct;
- training for staff involved in procurement and working in countries where bribery may be prevalent;
- due diligence assessment of agents, consultants and contractors;
- separation of duties (eg staff receiving gifts are not involved in decision-making relating to admissions, assessment or awarding honorary degrees);
- communication of the College’s/Service’s risk assessment and action plan to individuals responsible for working in those areas of activity;
- encouraging a culture of openness so that concerns about the appropriateness of gifts, hospitality and other conduct are openly discussed between managers and staff;
- cultural awareness training for staff and agents operating in certain countries;
- ensuring that staff ask for a receipt which details the reason for any payment made.
Colleges/Services should ensure that organisations and individuals other than employees who perform services for or on behalf of the University – including consultants, subsidiary companies, contractors and partner organisations – are aware of the University’s standards and expectations regarding bribery.
The University has agreed an Anti-Bribery Policy Statement for Third Parties performing services for or on behalf of the University which Colleges/Services should sent to third parties at the outset of any business relationship with them. Managers should also, as appropriate to the circumstances, take opportunities to remind and reinforce these standards to third parties on an ongoing basis.
Colleges/Services should also consider including clauses on conduct and bribery in contracts with suppliers, agents, consultants and contractors. Guidance should be sought from the Contracts Team in Insurance and Legal Services.
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