Anti-bribery policy statement for third parties performing services for or on behalf of the University
Before confirming the University’s agreement to a contract prepared by a third party (for example a partner organisation or research sponsor) which includes terms relating to the University’s compliance with the Bribery Act and anti-corruption practices and standards, advice should be sought from Insurance and Legal Services.
(1) The University’s Ethics Policy sets out the University’s intentions to maintain high ethical standards across all its activities.
(2) The University expects every business and individual performing services for it or on its behalf to do so in an honest and professional manner.
(3) The University does not tolerate any form of bribery, whether direct or indirect, by its agents, consultants, contractors, suppliers, subsidiaries, joint venture partners and any other third parties performing services for or on behalf of the University.
(4) All such third parties must comply with the University’s standards with regard to bribery and with the requirements of the Bribery Act 2010, and must ensure that their staff are required to comply with those standards and requirements and receive appropriate training. The University may require a written assurance from a third party of their compliance with the University’s standards and the requirements of the Act, including details of the anti-bribery measures that they have taken.
(5) Under the Bribery Act, a bribe is a “financial or other advantage” offered, promised or given to induce a person to perform a relevant function or activity improperly, or to reward them for doing so. The Act makes it a criminal offence to:
- offer, promise or give a bribe
- request, agree to receive or accept a bribe
- bribe a foreign official to obtain or retain business or an advantage in the conduct of business
- (by an organisation) fail to prevent bribery by those acting on its behalf in the UK or abroad to obtain or retain business or an advantage in the conduct of business for the organisation.
- Small payments made to government officials or others to make something happen, or happen sooner (commonly called facilitation payments) are likely to be unlawful bribes.
- Individuals should note that bribery is a criminal offence in the UK that may result in up to 10 years’ imprisonment and/or an unlimited fine for the individual and an unlimited fine for the organisation on behalf of which the bribery offence is committed.
(6) As part of its anti-bribery measures, the University is committed to proportionate, reasonable and bona-fide hospitality and promotional expenditure. The frequency and scale of any hospitality accepted by a third party should in general not be significantly greater than they or the University would be likely to provide in return. Any expenditure which does not comply with this principle must be authorised in advance by the appropriate University manager.
(7) The University will not conduct business with third parties that do not support the University’s anti-bribery objectives.
(8) The University reserves the right to terminate its contractual arrangements with any third party providing services for or on behalf of the University with immediate effect and without compensation for any loss where there is reasonable evidence that they/their staff have committed an act of bribery. Where appropriate, the University will include terms in its contracts with third parties requiring compliance with the University’s standards and with the requirements of the Bribery Act.
(9) All those providing services for or on behalf of the University are encouraged to report any suspected bribery to the University to the appropriate University manager.
The appropriate University manager will be the manager who has authorised/signed the contract with the third party on behalf of the University.