Fraud & bribery and gifts & hospitality

Fraud and bribery

Ethics Code Principle 2 - Integrity: 

  • Act in accordance with all relevant legislation and statutory requirements

In accordance with the School’s Ethics Policy (PDF), the School has a zero tolerance approach to all forms of fraud and bribery.  Employees and associated persons must not engage in any form of fraud and bribery in connection with or relating to any activity carried out on behalf of, or in the name of the School.  The School will investigate all allegations of fraud and bribery.  A Fruad Investigation Panel is appointed for full investigations and given the serious nature of allegations of fraud and bribery, the School reserves the right to suspend an employee while an investigation is being conducted.

What Constitutes bribery?

Under the Bribery Act 2010, the following are offences:

  1. A person is guilty of bribing where the person offers, promises or gives a financial or other advantage to another person, intends the advantage (i) to induce a person to perform improperly a relevant function or activity, or (ii) to reward a person for the improper performance of such a function or activity.
  2. A person is guilty of being bribed if the person requests, agrees to receive or accepts a financial or other advantage intending that, in consequence, a relevant function or activity should be performed improperly.
  3. relevant function is any function of a public nature; any activity connected with a business, trade or profession; any activity performed in the course of a person's employment; or any activity performed by or on behalf of a body of persons whether corporate or unincorporated.

Examples of bribery

Bribes, or advantages, can take many forms, but commonly take the form of:

  • Money
  • Discounts
  • Vouchers
  • Loans
  • Gifts
  • Travel
  • Accomodation
  • Hospitality
  • Preferential Treatment
  • Business Advantage


If you have a reasonable suspicion of actual or attempted bribery or fraud, you must submit a written report to the School Secretary, the Director of Finance and Facilities or the Finance Director. A register of the incidents of fraud and bribery is recorded.

If you are reporting suspected bribery or fraud in relation to another individual, the School will consider the protection of any complainant’s identity and any wishes to remain anonymous. However, this cannot be guaranteed. Reports of suspected bribery or fraud can also be made through the School’s whistleblowing hotline (link).

  1. Policy Against Bribery and Fraud (PDF)

  2. Financial Regulations (PDF)

  3. Anti Fraud and Bribery Training 

Face to face training sessions are also held periodically to register your interest please email the Head of Legal

Facilitation Payments  Guidance

This Facilitation Payments Guidance (PDF) is for staff and students who will be travelling overseas for any purpose, either research related or on regular school business and particularly those that are travelling to countries with high risk of corruption, although facilitation payments may also be made in the UK and Europe.

Facilitation payments are a type of bribe and are illegal under the UK Bribery 2010 and so should not be paid.  Facilitation payments are usually small, unofficial or covert payments which are sought in order to do a job properly or more quickly or for  preferential treatment, usually things you are already entitled to.  For example: customs clearance, work permits, licences, official documents and roadblocks.


Gifts and hospitality

Ethics Code Principle 2 – Integrity:

  • Be honest and truthful
  • Act in accordance with all relevant legislation and statutory requirements 
  • Be transparent and consistent in our decision making
  • Maintain our independence in engaging with outside parties

Staff may be offered gifts and hospitality in the course of their normal duties and they should be  recorded through gift registers held in each department and division. Staff should not accept gifts of money or monetary tokens and should be satisfied that all offers are appropriate and the value of the gift or hospitality is reasonable and proportionate. 

Staff should consult the full Gifts and Hospitality Procedure (DOC) for details of what to report, factors to consider, forms and templates for local registers, guidance on acceptable and unacceptable gifts and frequently asked questions.

For queries on gifts and hospitality please contact the Head of Legal