Company number: 12497951
6 Sutton Park Road, Sutton, SM1 2GD

Anti-Bribery and Corruption Policy

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.

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:

Authority	Name	Url
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.
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.
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.
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.
UK Government	Bribery Act 2010 The Bribery Act 2010 prohibits bribery in business and government.

Authority

Name

Url

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.

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.

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.

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.

UK Government

Bribery Act 2010
The Bribery Act 2010 prohibits bribery in business and government.

Offences Under the Bribery Act 2010

Title
Rule Compliance with the Bribery Act 2010 The School has a clear commitment to zero tolerance of bribery and corruption. All individuals associated with the School, including staff, students, contractors, partners, 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.

Title

Rule
Compliance with the Bribery Act 2010

The School has a clear commitment to zero tolerance of bribery and corruption. All individuals associated with the School, including staff, students, contractors, partners, 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.

Compliance Obligations for All School Stakeholders and External Entities

Title
Rule Adherence to the Bribery Act 2010 All members of the School, including governors, staff, and students, must familiarise themselves with the Bribery Act 2010 and adhere to the School’s anti-bribery policy. Any actions involving offering, accepting, or soliciting bribes—such as influencing admissions, assessments, or procurement decisions in exchange for gifts or favours—are strictly prohibited. Staff, students, and governors must declare conflicts of interest, which occur when personal interests may influence their professional duties (e.g., financial ties to suppliers). Third parties, such as contractors, must also comply with the School’s anti-bribery rules, and the School will perform due diligence to ensure this. Any suspected bribery must be reported immediately via confidential channels, with breaches leading to disciplinary action and possible legal reporting. Ensuring that all members of the School community understand and comply with the Bribery Act 2010 helps to maintain a culture of integrity and transparency. Strict rules around conflicts of interest, bribery in key processes like admissions and procurement, and reporting mechanisms protect the School’s reputation and ensure fair, ethical decision-making. Holding third parties to the same standards reinforces trust and compliance throughout all School-related activities. Clear reporting procedures and decisive consequences for breaches help deter misconduct and promote a safe and accountable environment.

Title

Rule
Adherence to the Bribery Act 2010

All members of the School, including governors, staff, and students, must familiarise themselves with the Bribery Act 2010 and adhere to the School’s anti-bribery policy. Any actions involving offering, accepting, or soliciting bribes—such as influencing admissions, assessments, or procurement decisions in exchange for gifts or favours—are strictly prohibited. Staff, students, and governors must declare conflicts of interest, which occur when personal interests may influence their professional duties (e.g., financial ties to suppliers). Third parties, such as contractors, must also comply with the School’s anti-bribery rules, and the School will perform due diligence to ensure this. Any suspected bribery must be reported immediately via confidential channels, with breaches leading to disciplinary action and possible legal reporting.

Ensuring that all members of the School community understand and comply with the Bribery Act 2010 helps to maintain a culture of integrity and transparency. Strict rules around conflicts of interest, bribery in key processes like admissions and procurement, and reporting mechanisms protect the School’s reputation and ensure fair, ethical decision-making. Holding third parties to the same standards reinforces trust and compliance throughout all School-related activities. Clear reporting procedures and decisive consequences for breaches help deter misconduct and promote a safe and accountable environment.

Mandatory Due Diligence and Management of Conflicts of Interest

Title
Rule Compliance with Policy and Declaration of Interests 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.

Title

Rule
Compliance with Policy and Declaration of Interests

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.

Audits and Review

Title
Rule Regular Review The institution shall conduct a comprehensive review of bribery risks at least annually, covering all key areas such as admissions, procurement, research funding, and external partnerships. This review will include an evaluation of existing controls, identification of new risks, and updates to the policy where necessary. Any significant findings or changes will be reported to the senior leadership and incorporated into strategic planning. Regular reviews are essential to ensure that the Anti-Bribery and Corruption Policy remains effective and responsive to evolving risks. Higher education institutions operate in dynamic environments, with new opportunities for bribery potentially emerging through changes in regulations, partnerships, or internal processes. A commitment to ongoing assessment allows for the early identification of vulnerabilities, ensuring that controls are updated, and risks are mitigated before any breach occurs. This proactive approach also strengthens compliance with the Bribery Act 2010 and OfS requirements.
Rule Focus on Academic Integrity The institution will enforce strict policies to protect academic integrity by ensuring all academic processes, including admissions, grading, awarding of degrees, and research evaluations, are free from any undue influence or bribery. Staff and students must declare any conflicts of interest, and any attempt to alter academic outcomes through bribery will result in immediate investigation and appropriate disciplinary action. A clear appeals process will be in place to address concerns related to academic integrity. Safeguarding academic integrity is crucial to maintaining the credibility and trustworthiness of the institution's qualifications and reputation. Bribery in academic processes compromises fairness, meritocracy, and the value of educational achievements, undermining the institution's mission. By addressing academic integrity directly in the policy, the institution demonstrates its commitment to impartial and ethical academic practices, ensuring that all academic outcomes are based solely on merit and not external pressures, thus upholding its standards and complying with legal and regulatory requirements.

Title

Rule
Regular Review

The institution shall conduct a comprehensive review of bribery risks at least annually, covering all key areas such as admissions, procurement, research funding, and external partnerships. This review will include an evaluation of existing controls, identification of new risks, and updates to the policy where necessary. Any significant findings or changes will be reported to the senior leadership and incorporated into strategic planning.

Regular reviews are essential to ensure that the Anti-Bribery and Corruption Policy remains effective and responsive to evolving risks. Higher education institutions operate in dynamic environments, with new opportunities for bribery potentially emerging through changes in regulations, partnerships, or internal processes. A commitment to ongoing assessment allows for the early identification of vulnerabilities, ensuring that controls are updated, and risks are mitigated before any breach occurs. This proactive approach also strengthens compliance with the Bribery Act 2010 and OfS requirements.

Rule
Focus on Academic Integrity

The institution will enforce strict policies to protect academic integrity by ensuring all academic processes, including admissions, grading, awarding of degrees, and research evaluations, are free from any undue influence or bribery. Staff and students must declare any conflicts of interest, and any attempt to alter academic outcomes through bribery will result in immediate investigation and appropriate disciplinary action. A clear appeals process will be in place to address concerns related to academic integrity.

Safeguarding academic integrity is crucial to maintaining the credibility and trustworthiness of the institution's qualifications and reputation. Bribery in academic processes compromises fairness, meritocracy, and the value of educational achievements, undermining the institution's mission. By addressing academic integrity directly in the policy, the institution demonstrates its commitment to impartial and ethical academic practices, ensuring that all academic outcomes are based solely on merit and not external pressures, thus upholding its standards and complying with legal and regulatory requirements.

Reporting Procedures for Policy-Related Actions

Title
Rule Reporting and Compliance with Bribery Act 2010 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.
Rule Whistleblower Protection This policy should be read in conjunction with the Whistleblowing Policy. Any individual (staff, student, or third-party) who reports concerns of bribery or corruption in good faith, whether proven or not, will be protected from retaliation or victimisation. This includes protection from dismissal, demotion, disciplinary action, harassment, or any form of unfair treatment as a result of their whistleblowing. The effectiveness of any Anti-Bribery and Corruption Policy relies on a culture where individuals feel confident to report wrongdoing without fear of reprisal. Protecting whistleblowers ensures that concerns are raised early, preventing potential corruption from escalating. This protection also encourages an open and transparent working environment, aligning with ethical and legal standards. Without such protections, individuals may hesitate to report issues, allowing unethical behaviour to persist unchecked.

Title

Rule
Reporting and Compliance with Bribery Act 2010

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.

Rule
Whistleblower Protection

This policy should be read in conjunction with the Whistleblowing Policy. Any individual (staff, student, or third-party) who reports concerns of bribery or corruption in good faith, whether proven or not, will be protected from retaliation or victimisation. This includes protection from dismissal, demotion, disciplinary action, harassment, or any form of unfair treatment as a result of their whistleblowing.

The effectiveness of any Anti-Bribery and Corruption Policy relies on a culture where individuals feel confident to report wrongdoing without fear of reprisal. Protecting whistleblowers ensures that concerns are raised early, preventing potential corruption from escalating. This protection also encourages an open and transparent working environment, aligning with ethical and legal standards. Without such protections, individuals may hesitate to report issues, allowing unethical behaviour to persist unchecked.

Induction and Continuous Training on the Bribery Act 2010

Title
Rule Policy Induction and Training 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.

Title

Rule
Policy Induction and Training

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.

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.

Title
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.
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.
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.
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.
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.

Title

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.

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.

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.

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.

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.