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Business without Bribery - Information for Third Parties

Information for University partners, contractors and other third parties about the requirements of the UK Bribery Act 2010 and related University policies and procedures.

Northumbria University strives to maintain high ethical standards across all its activities.  The University expects all third parties acting on its behalf to act with integrity and carry out their activities in an honest and professional manner.

Bribery and the Bribery Act 2010

The UK Bribery Act 2010 came into force on 1 July 2011 and sets out offences relating to:

  • offering or giving a bribe (“active bribery”)
  • requesting or accepting a bribe (“passive bribery”)
  • bribing foreign public officials, wherever that takes place
  • failing to prevent bribery.

Under the Bribery Act 2010, it is a criminal offence to give or receive (or promise to give or receive) a bribe anywhere in the world.

The University’s Anti-Fraud & Bribery Policy incorporates the University’s stance on bribery and outlines expectations of staff and third parties and gives guidance on how concerns should be reported, some of which is extracted below.

University Standards & Expectations

The University will not tolerate any form of fraud, bribery or corruption by its agents, consultants, contractors, suppliers, subsidiaries, joint venture partners and any other third parties performing services for, or on behalf of, the University.

All third parties must comply with the University’s standards with regard to bribery and with the requirements of the Bribery Act 2010, by avoiding all activities which are fraudulent or corrupt including bribery, e.g.:

  • acting dishonestly to cause a loss to the University or others or to make a gain for themselves and/or parties known to them;
  • offering (including promising to offer), requesting or receiving (including promising to receive) a bribe at any time;
  • the payment of facilitation payments; or
  • abusing their position.

As appropriate, third parties acting on behalf of the University will be subject to:

  • proportionate due diligence procedures;
  • contractual clauses requiring compliance with the University’s standards and with the requirements of the Bribery Act;
  • contract termination (with immediate effect and without compensation) where there is reasonable evidence that they/their staff have committed an act of bribery.

Facilitation payments

In many countries, it is customary business practice to make payments or gifts of small value to junior government officials in order to speed up or facilitate a routine action or process. These payments, often known as “facilitation payments” or “grease payments” are illegal under the Bribery Act 2010 and should never be paid unless personal safety is at risk.

The Head of Governance must be informed if a third party makes a facilitation payment whilst acting on behalf of the University. 

Gifts and Hospitality

Gifts and hospitality must be reasonable and proportionate, both in frequency and scale, to the nature of the relationship and must not exceed normal business courtesy. 

While acting on the University’s behalf, third parties must not offer gifts and hospitality, either to University staff or any other party, with the intent of influencing a decision.  During procurement exercises, third parties involved in bidding for a University contract should not offer any gifts or hospitality to University staff. 

All gifts and hospitality offered to University staff will be recorded in a Gifts & Hospitality Register, even if declined.

Reporting a concern

Third parties are encouraged to use the process below to report any suspected fraud, bribery or other corrupt behaviour.

In the first instance, staff employed by contractors and other third parties should notify their Line Manager of any concerns and/or the main University contact for the project or contract.  

Concerns should be communicated in writing but may be made orally in exceptional circumstances.  The report should provide:

  • a brief description of the alleged irregularity,
  • the loss (or potential loss) involved,
  • the individual(s) possibly involved and
  • any evidence supporting the concern.

If, for any reason, reporting via the Line Manager or main University contact is considered inappropriate (e.g. if the concern relates to them) or their response is considered to be unsatisfactory then a report may be made directly to the Head of Governance.  The concern will then be treated under the University’s Public Interest Disclosure (Whistleblowing) Policy.

Further guidance on the University’s approach to Fraud, Bribery and Corruption can be obtained by contacting the Head of Governance or Risk Manager. 

 

Last updated:  November 2017  


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