Anti-Bribery and Corruption Policy
Contents
1. Policy Statement
The Bribery Act 2010 came into effect on April 2011, superseding previous legislation. Notably, it made failing to prevent bribery a corporate offence. It also made bribing a foreign public official an individual criminal offence.
The University of Glasgow is committed to conducting its activities with the highest ethical standards. It expects its employees and representatives to reflect this commitment in their work, behaving honestly and with personal integrity. The University will not tolerate bribery or corruption and is committed to preventing bribery and corruption by its staff and by any party acting on its behalf.
Bribery or corruption by University staff will be treated as a serious disciplinary offence. Should it occur, the University will take firm action, which may include dismissal and legal action.
2. Scope
This policy applies to every member of staff, including temporary staff, agency staff, voluntary workers and staff of subsidiary companies. It applies to all activities of the University.
The University expects anyone acting on its behalf to have procedures in place to prevent bribery and corruption. This includes agents and others who represent the University, and suppliers who perform services for the University in the UK and in other countries.
3. Standards
Staff and other persons who act on behalf of the University are expected to adhere to the following standards:
3.1 They must not seek a financial or other advantage for the University through bribery, they must not give - or offer to give - a bribe, and they must not receive - or agree to receive - a bribe.
3.2 They must not make or accept facilitation payments.
3.3 They must not engage in any form of fraudulent activity.
3.4 They must abide by the University’s financial regulations on gifts and hospitality. These require that, with the exception of low value gifts such as a gift worth less than £25 or hospitality worth less than £50, employees must seek written permission from their Head of School/Institute/Department before accepting gifts or hospitality from potential or existing suppliers or their agents. Under no circumstance must the receipt of gifts or hospitality influence the choice of a supplier, and, if there is any doubt, then gifts and/or hospitality should be refused.
3.5 They must report any suspicion of bribery or corruption; either to their line-manager and/or through the University’s Whistleblowing Policy. A deliberate failure to report suspicions of corruption, or to conceal corrupt action by others, will be subject to disciplinary action.
4. Training and its objectives
The University has developed online training material to assist staff in understanding their duties in terms of UK Anti-Bribery and Corruption legislation. This course should be completed by all staff, including agents employed by the University, where their duties may place them in a situation where they might be exposed to bribery or corruption. It is essential for anyone doing international travel on behalf of the University, involved with any Procurement activity, and staff involved in areas such as international partnerships, student recruitment, student registration and estates development.
The objectives of the training are that participants will be able to:
- Understand what bribery is (direct and indirect forms of Bribery).
- Understand the Bribery Act 2010.
- Identify instances of corruption and feel confident about reporting them.
- Anticipate difficult situations and take the necessary steps to avoid them.
- Deal with ethical dilemmas in the workplace.
- Understand that the onus is on the individual to comply with the Act.
- Apply the knowledge acquired in the course to comply with the Act.
- Inculcate respect for the law and inspire an ethical approach amongst all colleagues.
- Demonstrate clear understand of the legislation through 100% pass rate for online assessment.
Online Training Course: Click this link to access the training
5. Responsibilities
5.1 The University Court is responsible for this policy.
5.2 Chief Operating Officer is responsible for :
- communicating the policy to staff.
- ensuring the policy is reviewed at least once in every 2 years, taking account of any relevant legislation and/or changing circumstances.
- conducting, at least once in every 2 years, an assessment of the bribery and corruption risks faced by the University.
- ensuring an audit, at least once in every 5 years, of the implementation of this policy
5.3 Heads of School / Directors of Institute / Heads of Department are responsible for
- ensuring that staff in their area of responsibility are aware of this policy and that relevant staff undertake the University’s online training.
- reporting any suspicion of bribery or corruption; either to their line-manager and/or through the University’s Whistleblowing Policy.
5.4 All employees are expected to
- adhere to the University’s anti-bribery and corruption policy.
- undertake the University’s online training, where their duties may place them in a situation where they might be exposed to bribery or corruption.
- report any suspicion of bribery or corruption; either to their line-manager and/or through the University’s Whistleblowing Policy.
6. Exceptions
The University recognises that exceptional circumstances might arise in which a member of staff’s refusal to offer or accept a bribe might cause immediate personal danger to that individual. In such circumstances, a payment may be offered or accepted, but this must be reported and recorded at the time of the event or as soon as possible thereafter.
Reviewed December 2022