This policy is available to
download as a pdf file here.
1.1 This policy applies to all
members of the University of Wolverhampton (the "University"). For
the purposes of this policy, the term "member" means all members of
University staff including permanent, fixed term and temporary
staff, governors, students, secondees, any third party
representatives, agency workers, volunteers, interns, agents and
sponsors engaged with the University in the UK or overseas. This
policy also applies to all members of staff employed by any of the
University's subsidiary companies.
1.2 All contractors and agents
acting for or on behalf of the University should be made aware of
this policy, particularly during any procurement process.
Reasonable due diligence must be carried out to ensure they are not
acting in a way contrary to the University's policy or
1.3 Third parties acting for the
University are expected to take appropriate action should it be
suspected or discovered that fraudulent activity or bribery is
1.4 Any University member who is
found to be in breach of this policy will be subject to
disciplinary procedures. Members are reminded that fraud and
bribery are also criminal offences. The University also reserves
the right to seek redress via civil proceedings against individuals
whose fraudulent acts or omissions have resulted in financial loss
to the University. This is regardless of whether the individual was
1.5 This policy should be read in
conjunction with the University's policies on conflict of interest,
financial regulations, whistleblowing and declaration of
1.6 This policy has been developed
to comply with the provisions of the Bribery Act 2010 and in
particular addresses the following:
This policy addresses the
principles under the Bribery Act 2010.
2.1 The University of
Wolverhampton does not participate in any form of bribery, fraud or
corruption. The University is committed to safeguard the proper use
of the University's finances and resources and operates a zero
tolerance policy in respect of bribery.
This means that people acting or
working for the University must never:
2.2 What are bribery and
Corruption is the misuse of public
office or power for private gain or misuse of private power in
relation to business outside the realm of government.
Bribery is the means of offering,
promising, giving, requesting or accepting anything of value (for
example, money, gifts, hospitality, favours, information, job
opportunities or any other benefit or advantage) with the purpose
of improperly obtaining an advantage. The University undertakes its
business worldwide and this policy applies without geographical
The Bribery Act 2010 introduced
1. Offering a bribe (applies to
both individuals and corporations, i.e. the University);
2. Receiving a bribe (applies
to both individuals and corporations);
3. Bribing a foreign public
official (applies to both individuals and corporations);
4. Failing to prevent bribery
(applied to corporations only).
2.3 When and how to
The prevention, detection and
reporting of bribery is the responsibility of all members of the
If you are in a situation and
unsure whether you are being offered a bribe or are concerned your
conduct could suggest you are offering a bribe, consider the
If the answer to any of the
following questions is "no" or "don't' know" then stop and seek
advice from the Secretary to the Board and Director of
Corporate Governance before acting.
Central to the operation of this
policy is transparency in the University's business dealings. It is
therefore imperative if you receive an offer that may be
interpreted as a bribe, a payment or inducement this must be
declared to the Secretary to the Board and Director of Corporate
If you have suspicions of a breach
of the Act by others you must report this using the University's
2.4 What are the
consequences of bribery?
Bribery is a serious matter and a
criminal offence. An individual who breaches the Bribery Act
As an institution we risk, amongst
The University of
Wolverhampton does not make facilitation payments of any
A facilitation payment is a payment
of gift, often of small value, made to a public official to speed
up or secure the performance of a routine, governmental action
which the public official has to perform in any event. A
facilitation payment is a bribe. In some countries, such practices
may be seen as normal practice but under the Bribery Act,
facilitation payments are illegal. In particular, staff who are
performing duties intentionally must take care they do not accept
or make a facilitation payment.
Even if a facilitation payment is
offered and/or accepted outside of the UK, the University will
still be in breach of the Bribery Act. If you are asked to make a
facilitation payment or are concerned the transaction may resemble
a facilitation payment, you must contact the Secretary to the Board
Hospitality, entertainment and
gifts that are frequent, lavish or extravagant will be perceived to
have influenced the recipient.
This policy is not designed to
prevent staff from receiving hospitality or gifts but to set out
clear guidance to avoid doubt and confusion. Hospitality and gifts
should be both sensible and proportionate to the circumstances. The
University expects you to disclose the receipt of any
gift/hospitality in the course of your duties.
Members of the University may not
directly, or through others, offer or give any gift, hospitality,
money or other thing of value to any official, employee or
representative of any supplier, customer or any other organisation
if doing so could reasonably give the appearance of influencing the
organisations' relationship with the University. To do so could
seriously damage the University's reputation and you may also be
breaking the law.
Members of the University must not
provide gifts to, or receive them, from governmental officials.
Members of the University may do
3.2 Receiving Gifts and
Staff must not accept any gifts or
hospitality, regardless of value, which may influence or be
perceived to be seen to influence situations such as examination
results, validation trips, awarding of contracts, use of the
University's assets or facilities or to benefit another personally
In the course of duties, staff may
find themselves in a position where they are in receipt of
gifts/hospitality. In accordance with the Bribery Act 2010,
received hospitality and gifts must be both sensible and
3.3 How do I judge what is
an "acceptable" gift or hospitality?
Unless you have been instructed
otherwise, staff may accept the following:
Any other gift which does not fall
within the above criteria should be politely declined.
3.4 What if I have no
warning of the hospitality/gift?
There may be occassinos where you
have no warning that a gift or hospitality will be offered.
There are some circumstances, such
as overseas business trips, where to refuse a gift could cause
offence to your hosts. In these circumstances,
the gift/hospitality can be accepted but must
be disclosed on your return.
If you are travelling overseas on a
validation trip, you are not permitted to accept any hospitality
or gifts. To avoid any offence being caused, you should
communicate this to your hosts prior to travelling. Guidance on how
to do this can be given via the International Office.
3.5 What is the procedure
for disclosing hospitality and gifts?
If you are offered hospitality or
gifts, the following procedure should be used.
In any event of any doubt about the
probity of such hospitality, advice should be sought from the
Secretary to the Board and Director of Corporate Governance.
3.6 After disclosing, can I
keep a gift?
Gifts, other than those of a
nominal value, must be recorded in the University hospitality and
The normal expectation is that
gifts of this kind are passed to the University.
The University may either retain
the gift and display it in the University (this may be the case
with plaques, trophies etc) or may sell the gift and the proceeds
will be donated for the benefit of students.
In exceptional circumstances a gift
that is personal in nature may be retained subject to an
appropriate agreement with the University.
4. Useful Contacts
Secretary to the Board and Director
of Corporate Governance - Tony Lee, email@example.com or 01902
Finance Director - Andy Holding,
or 01902 322586
Approved by Board of Governors, 5th July 2012
University of Wolverhampton, Wulfruna Street, Wolverhampton, WV1 1LY
Course enquiries: 0800 953 3222, General enquiries: 01902 321000 | Email: firstname.lastname@example.org
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