Version Number	4
Issue Date (Last Review Date)	27/08/2021
Review Date	27/08/2022
Author	Andrew Hammond (Group CEO)
Approved by	Andy Cheshire (MD)

Introduction

It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any non-employee who breaches this policy may have their contract terminated with immediate effect.

Policy Scope

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

This policy does not form part of any employee’s contract of employment and we may amend it at any time. It will be reviewed regularly.

We expect all employees to complete the ‘Bribery Act’ e-learning module as part of their mandatory training.

Definitions

What is Bribery?
“Bribe” means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.

“Bribery” includes offering, promising, giving, accepting or seeking a bribe.

All forms of bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, please raise it with your line manager.

Specifically, you must not:
• give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;
• accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else; or
• give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure.

You must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

Process

Gifts and Hospitality
This policy does not prohibit the giving or accepting of reasonable and appropriate gift or hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.

A gift or hospitality will not be appropriate if it is unduly lavish or extravagant or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).

Gifts or hospitality must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift or hospitality. Gifts or hospitality must not include cash or cash equivalent (such as vouchers) or be given in secret. Gifts or hospitality must be given in the Company name, not your name. Any gift or hospitality with a value of £25 or more, must be declared and logged on the Company Gifts & Hospitality Register.

Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers and business partners.

Records
You must declare and keep a written record of all hospitality or gifts given or received within the Company’s Gift’s & Hospitality register which is held centrally at Instructus. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.

All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.

You are expected to advise your line manager of any gifts or hospitality you have given or received. Line Managers will liaise with the Sales & Marketing Director or the Chief Operating Officer to update the register.

How to raise a concern?
If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify your line manager as soon as possible.
Related Policies
• Conflict of Interest Policy
• Malpractice & Maladministration Policy
• Invigilation Policy and Procedure
• Plagiarism and Collusion Policy
• Sanctions Policy