POLICY: Codes of Conduct - Anti-Bribery and Corruption Policy POLICY URL: https://lsi-ac.uk/policy/83e1d637-aff1-4a5e-a5e0-f89efbfa579e POLICY STATEMENT: The School is committed to conducting its activities with the highest standards of ethical conduct and in compliance with all relevant legal and regulatory requirements. The 'Anti-Bribery and Corruption Policy' underscores this commitment and serves as a testament to our unwavering stance against any forms of bribery and corruption. This policy outlines the responsibilities of the School's members and its broader community to prevent, identify, and address potential instances of bribery and corruption. It applies to all staff, students, contractors, and external partners associated with the School, ensuring that our operations are carried out with integrity, transparency, and accountability. POLICY PRINCIPLES: ------------------ - Integrity : Upholding the highest ethical standards in every action and decision; - Zero Tolerance : Implementing a zero-tolerance approach to bribery and corruption; - Compliance : Adhering strictly to all relevant anti-bribery and corruption laws; - Responsibility : Holding every member of the School accountable for ethical conduct; - Transparency : Ensuring openness in all our dealings and procedures; - Training : Providing comprehensive training to ensure understanding and awareness of anti-bribery measures; - Reporting : Encouraging prompt and confidential reporting of any suspected bribery or corruption; - Prevention : Proactively implementing measures to prevent unethical conduct; - Investigation : Rigorously investigating any allegations of bribery or corruption; - Enforcement : Taking decisive action against any breaches of policy; - Review : Regularly reviewing and updating anti-bribery and corruption measures; - Partnerships : Expecting ethical behaviour from all external partners and contractors. REGULATORY CONTEXT: ------------------ This Policy has been developed in line with the applicable laws, regulations, regulatory advice, and sector best practices, including the following: R1. Office for Students (OfS): Regulatory Notices and Advice - Regulatory notices are additional information about OfS' regulatory requirements and are part of the regulatory framework. Regulatory advice helps providers understand and meet OfS requirements. R2. Quality Assurance Agency (QAA): The Quality Code - This code represents a shared understanding of quality practice across the UK higher education sector, protecting public and student interests and championing the UK's reputation for quality. R3. Office for Students (OfS): Regulatory framework for higher education in England - This framework outlines OfS' primary aim to ensure positive outcomes for students, including access, success, and progress in higher education. It covers quality academic experience, progress into employment, and value for money. R4. UK Government: Bribery Act 2010 - The Bribery Act 2010 prohibits bribery in business and government. R5. UK Government: Higher Education and Research Act 2017 (HERA) - A UK legislation that reformed the higher education and research sector, particularly by establishing the Office for Students and UK Research and Innovation. METRICS AND KPIS: ------------------ The following metrics will be measured and regularly reviewed as key performance indicators for the School to ensure the effectiveness of this policy and associated operations: M1. Conflict of Interest Declarations: Monitor the number of conflict of interest declarations received from staff, students, and partners annually, aiming for a 100% declaration rate. Proper declaration of conflicts of interest helps prevent bribery and corruption by ensuring transparency. M2. Incident Reporting Rate: Monitor the number of bribery or corruption incidents reported compared to the total number of staff, students, contractors, and external partners. A higher reporting rate indicates effective awareness and willingness to address potential issues, reflecting the policy’s impact. M3. Investigation Timeframe: Measure the average time taken to investigate reported bribery and corruption incidents from the date of report to resolution, aiming for a 45-day resolution period. Timely investigations ensure quick resolution and demonstrate commitment to addressing issues promptly. M4. Percentage of New Joiners Completing Induction: Measure the percentage of new staff, students, and partners who complete induction on anti-bribery and corruption within 30 days of joining. Induction ensures that new members are aware of and understand the policy from the outset. M5. Training Completion Rate: Track the percentage of staff, students, contractors, and external partners who complete mandatory anti-bribery and corruption training annually. Training ensures that all members are informed about the policy, legal requirements, and how to act in compliance with the anti-bribery standards. SECTION 1: Offences Under the Bribery Act 2010 ------------------ 1.1. Compliance with the Bribery Act 2010 (by All staff and students): All individuals associated with the School must comply with the Bribery Act 2010, which prohibits offering, giving, or receiving bribes. Section 1, for example, defines bribery with respect to ‘promises or gives a financial or other advantage to another person’ and ‘to induce a person to perform improperly a relevant function or activity’, or ‘to reward a person for the improper performance of such a function or activity.’ For a thorough understanding of all bribery offences, refer to the full text of the Bribery Act 2010 and the related guidance available at Bribery Act 2010 Guidance ; The Bribery Act 2010 sets out legal requirements to prevent bribery and corruption. Ensuring that everyone associated with the School understands and adheres to these rules promotes ethical behaviour and safeguards the School’s integrity. SECTION 2: Compliance Obligations for All School Stakeholders and External Entities ------------------ 2.1. Adherence to the Bribery Act 2010 (by All staff and students): All members of the School community, including governors, staff, and students, must familiarise themselves with both the legal requirements and the principles of the Bribery Act 2010. Any conduct that breaches the Act is strictly prohibited and will lead to disciplinary action. The School will also ensure compliance by third parties and will report any breaches to law enforcement agencies. For any questions, please contact the President; Understanding and adhering to the Bribery Act 2010 ensures ethical behaviour and legal compliance within the School. Enforcing these rules helps maintain integrity and transparency, and reporting violations upholds legal standards and protects the School’s reputation. Providing a contact point for questions supports clarity and guidance on compliance. SECTION 3: Mandatory Due Diligence and Management of Conflicts of Interest ------------------ 3.1. Compliance with Policy and Declaration of Interests (by All staff and students): All staff must adhere to this policy and ensure that their direct reports are aware of it. Due diligence is required at all times. This includes declaring all gifts, hospitality, and any actions that could potentially breach the Act. Please refer to the Declaration/Management of Interests section in the Governance Statement. The School will rigorously enforce all relevant laws; Ensuring compliance with this policy and the Declaration of Interests promotes transparency and integrity. Declaring gifts and potential conflicts of interest helps prevent breaches of the law and maintains the School’s ethical standards. Strict enforcement reinforces legal and policy adherence across the School. SECTION 4: Reporting Procedures for Policy-Related Actions ------------------ 4.1. Reporting and Compliance with Bribery Act 2010 (by President): Any actions potentially engaging this policy must be reported to the President, who acts on behalf of the Board of Governors, which holds overall compliance responsibility. The President will evaluate whether the action involves a breach of the Bribery Act 2010, considering the law’s focus on advantage and impropriety, along with all relevant circumstances. The President will determine necessary actions, which may include disciplinary measures and informing law enforcement agencies. The Board of Governors will review these actions as part of its oversight and annual review process; Reporting actions to the President ensures proper evaluation and compliance with the Bribery Act 2010. The President’s assessment guarantees that any potential breaches are addressed in accordance with the law and School policies. Involving the Board of Governors in the review process upholds transparency and accountability in managing compliance and disciplinary matters. SECTION 5: Induction and Continuous Training on the Bribery Act 2010 ------------------ 5.1. Policy Induction and Training (by Executive Committee): This policy must be included in the staff handbook and covered during induction. The Director of Operations will organise relevant ongoing training; Including the policy in the staff handbook and during induction ensures that all staff are aware of and understand the policy from the start. Ongoing training, arranged by the Director of Operations, reinforces the policy’s importance and keeps staff updated on any changes, ensuring continuous compliance and understanding.