The provisions of the Bribery Act 2010 have increased the need for vigilance in this area, as the University and/or its staff may be rendered liable for prosecution if evidence of receiving or offering bribes or inducements can be demonstrated. This extends to those over whom the University is deemed to have control, such as overseas agents. Further information on the Bribery Act can be found at the link above.
In order to protect staff and the reputation of the University from accusations of bribery or corruption staff are not permitted, directly or indirectly, to accept any gift, hospitality, reward or other benefit from any source (including organisations, students, other employees and members of the public) with whom s/he has been brought into contact or maintains contact only by reason of the duties for which they are employed by the University except in the following circumstances:
- Occasional gifts which are regarded as trivial and where the nominal value received by any one person is under £10, e.g. diaries, calendars, pens, etc.. (Within some Faculties/Directorates where gifts of this nature are regularly received from a variety of sources it has been traditional for the gifts to be collected and raffled in order to raise money for charity. This is acceptable as long as the PV Dean or Director is agreeable to taking responsibility for ensuring that the administration of such events is properly conducted.).
- Conventional hospitality, e.g. annual dinner of a body with which staff have day-to-day contact, or working lunches in the course of official visits, where the frequency and the total cost of hospitality is reasonable and would not be construed by an impartial observer as affecting the employee's judgement regarding the work for which they are employed. This kind of hospitality will often be reciprocated by the University. Hospitality or benefits of this kind from students - including student clubs/societies - may be accepted where the nature, regularity or value of the hospitality is reasonable and would not be construed by an impartial observer as affecting the employee's judgement regarding the work for which they are employed. (Employees who are in any doubt about the nature, regularity or value of any such hospitality or benefit must use their discretion but seek advice from their line manager if in doubt and record the outcome in writing. In cases of corporate hospitality it would normally be expected, for example, that any hospitality where the value exceeds £100 be referred for authorisation. In the case of recognised corporate hospitality declared to the appropriate PVC Dean, Director, Vice-Chancellor’s Group or Chair of Governors, authorisation would normally be granted up to a notional value of £300 per annum. Staff are required to keep a written record of all cases where gifts or hospitality have been provided, together with appropriate written evidence that authorisation has been obtained where relevant).
- Where a more valuable gift or benefit is offered from which the University in general might benefit, rather than an individual employee, acceptance will be at the discretion of the Vice-Chancellor and should be referred to the External Relations Director.
Staff responsible for the purchase of supplies, equipment or services must take particular care to ensure that there can be no criticism that unequal treatment has been given to suppliers involved in tendering processes through the acceptance of gifts or other benefits. Staff should always bear in mind the need not to behave so that the impression might be given or interpreted by any member of the public, student or organisation with whom they deal that they may be influenced by any gift, benefit or behaviour to show favour or disfavour to any person or organisation in respect of the work for which they are employed.
If a member of staff is in any doubt as to the propriety of receiving any gift or hospitality then the employee must consult their PVC Dean or Director. Subject to the exceptions noted in 1 - 3 above, all gifts, hospitality and benefits whether provisional, given, received or declined should be recorded on the current Gifts and Hospitality Register. It is the responsibility of the member of staff in receipt of or providing a gift or hospitality to record this on the register in a timely manner. Employees who are found not to have acted in accordance with this policy may be disciplined and in serious cases may be dismissed on the grounds of gross misconduct.
Reviewed February 2018
