Code of conduct for staff

[1] The University is committed to the prevention of bribery¹ and will not tolerate bribery or other improper conduct, both inside the United Kingdom and abroad, by employees or other individuals or organisations who perform services for or on behalf of the University.

[2] The University is committed to the highest standards of openness, probity and accountability. It seeks to conduct its affairs in a responsible manner taking into account the requirements of the funding bodies and the standards in public life set by the Committee on Standards in Public Life (see Appendix A).

[3] The Code of Conduct applies to all employees and workers².

[4] The guiding principles to be followed at all times by employees must be:

• their conduct should not create suspicion of any conflict between their official duty and their private interest;
• their actions must not be influenced by a benefit (eg a gift or hospitality) offered or received to show favour or disfavour to any person or organisation, and nor should they give the impression (to any member of the public, or to any organisation with whom they deal, or to their colleagues) that they have been (or may have been) influenced by a benefit offered or received to show favour or disfavour to any person or organisation;
• their actions must not induce or reward someone to perform a role or function improperly.

[5] Employees should not accept any gifts, rewards or hospitality (or have them given to members of their families) from any organisation or individual with whom they have contact in the course of their work that would cause them to reach a position whereby they might be, or might be deemed by others to have been, influenced in making a business decision as a consequence of accepting the gift or hospitality.

[6] While there is no requirement to report one-off token gifts (of a value up to £20), employees should seek advice from their line manager if:

• they are offered or receive gifts of higher value; or
• they receive a succession of small gifts within a short period of time; or 
• otherwise have any concern that there is an intention to influence them to change their behaviour or act improperly.

In such circumstances, the employee should record the offer and/or acceptance of the gift promptly in writing to their Director of Faculty Operations Manager/Director of Professional Service (or other notified manager)³.

[7] Where hospitality is offered, the frequency and scale of hospitality accepted should not generally be significantly greater than the University would be likely to provide in return. If the frequency or scale of hospitality offered or provided is such that the employee has any concern that there is an intention to influence them to change their behaviour or act improperly, they should seek advice from their line manager and record the offer and/or acceptance of the gift promptly in writing to their Director of Faculty Operations Manager/Director of Professional Service (or other notified manager).

[8] The tests to be applied are:

• whether in all the circumstances - recognising (where appropriate) cultural expectations and accepted standards within the sector - the gift or hospitality is reasonable and justifiable; and
• what is the intention behind the gift.

When it is not easy to decide between what is and what is not acceptable in terms of gifts or hospitality, advice sought from the employee’s line manager.

[9] Depending on the circumstances, the appropriate action may be to:

• accept and keep the gift or hospitality;
• accept the gift but raffle it among colleagues and donate the money to charity;
• accept the gift but share it with colleagues;
• politely decline the gift or hospitality;
• make clear to the donor that the recipient of the gift will not be involved in decision making relating to business relations between the University and the donor.

[10] Employees should also take account of their responsibilities under other related University policies and procedures, including:

• Prevention of bribery and other improper conduct: guidance for Colleges and Services
• Fraud Policy
• Public Interest Disclosure Policy and Procedure
• Code of professional conduct: Relations between staff and students and relations between staff
• Financial Regulations relating to Procurement, the Procurement Manual and the Code of Purchasing Practice (section C2.2 of Financial Handbook)
• Ethics Policy

[11] The prevention, detection and reporting of bribery and other forms of corruption and improper conduct are the responsibility of all employees. All individuals covered by this Code of Conduct are required to avoid any activity that might lead to, or suggest, a breach of this Code of Conduct.

[12] Employees have a responsibility to the University to report to their Faculty Pro-Vice-Chancellor/Director of Professional Service (or other notified manager) any concerns they may have about possible breaches of this Code of Conduct, including potential improper conduct by individuals or organisations outside the University (for example, potential suppliers, donors or students). The Public interest disclosure policy should be used if it is not appropriate to report concerns to the Faculty Pro-Vice-Chancellor/Director of Professional Service.

[13] Employees who breach this Code of Conduct are liable for disciplinary action which may lead to their dismissal.

(1) Under the Bribery Act 2010, 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 public official to obtain or retain business or a business advantage
• (by an organisation) fail to prevent bribery by those acting on its behalf (‘associated persons’) to obtain or retain business or a business advantage 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 bribes and unlawful under the Act.

See our prevention of bribery guidance for examples of behaviour which may be considered as bribery under the Act.

(2) This includes temporary workers, other individuals paid by claim and agency worker (hereinafter referred to as ‘employees’). The University has a similar statement for third parties who perform services for or on behalf of the University.

(3) A register of gifts offered and/or received, other than one-off token gifts which do not have to be reported, will be maintained by the University for audit purposes.

The Committee on Standards in Public Life (www.public-standards.gov.uk) has set out, for the benefit of all who serve the public in any way, seven principles which apply to all aspects of public life.

• Selflessness: Holders of public office should act solely in terms of the public interest. They should not do so in order to gain financial or other material benefits for themselves, their family, or their friends.
• Integrity: Holders of public office should not place themselves under any financial or other obligation to outside individuals or organisations that might seek to influence them in the performance of their official duties.
• Objectivity: In carrying out public business, including making public appointments, awarding contracts, or recommending individuals for rewards and benefits, holders of public office should make choices on merit.
• Accountability: Holders of public office are accountable for their decisions and actions to the public and must submit themselves to whatever scrutiny is appropriate to their office.
• Openness: Holders of public office should be as open as possible about all the decisions and actions that they take. They should give reasons for their decisions and restrict information only when the wider public interest clearly demands.
• Honesty: Holders of public office have a duty to declare any private interests relating to their public duties and to take steps to resolve any conflicts arising in a way that protects the public interest.
• Leadership: Holders of public office should promote and support these principles by leadership and example.