Bribery is a criminal offence. Christ Church prohibits any form of bribery. We require compliance, from everyone connected with our institutional activities, with the highest ethical standards and anti-bribery laws applicable. Integrity and transparency are of utmost importance to us and we have a zero tolerance attitude towards corrupt activities of any kind, whether committed by Christ Church employees or by third parties acting for or on behalf of Christ Church.
It is prohibited, directly or indirectly, for any employee or person working on our behalf to offer, give, request or accept any bribe i.e. gift, loan, payment, reward or advantage, either in cash or any other form of inducement, to or from any person or company in order to gain commercial, contractual or regulatory advantage for Christ Church, or in order to gain any personal advantage for an individual or anyone connected with the individual in a way that is unethical.
If we suspect that a member of staff has committed an act of bribery or attempted bribery, an investigation will be carried out and, in line with our disciplinary procedure where appropriate, action may be taken against the member of staff which may result in their dismissal, or the cessation of our contractual arrangements with a company.
If as an employee or person working on our behalf, a member of staff suspects that an act of bribery or attempted bribery has taken place, even if the member of staff is not personally involved s/he is expected to report this to the relevant College Officer. They may be asked to give a written account of events.
Staff are reminded of Christ Church’s Whistle-blowing policy which is available in the Staff Handbook, or upon request.
Gifts and Hospitality
Christ Church realises that the giving and receiving of small gifts and occasional hospitality as a reflection of friendship or appreciation, where nothing is expected in return, may occur. This does not constitute bribery where it is proportionate. However, all gifts with a value in excess of £15 must be reported to the appropriate College Officer and recorded.
If a member of staff or anyone working on our behalf in connection with our institutional activities is in any doubt as to whether offering or receiving a gift or hospitality is a reflection of friendship or appreciation or, could be construed as a bribe, then they should seek prior written approval from the relevant College Officer.
As the law is constantly changing, this policy is subject to review and Christ Church reserves the right to amend this policy without prior notice.
11 July 2011