Anti Bribery

We value our reputation and commitment to maintaining the highest level of ethical standards. The actions and conduct of our agents are key to maintaining these standards.

A bribe is a financial or another type of advantage that is offered or requested with the:

intention of inducing or rewarding improper performance of a function or activity;
or knowledge or belief that accepting such a reward would constitute the improper performance of such a function or activity.

What is prohibited?

A criminal offense will be committed under the Bribery Act 2010 if the agent or sub agency offers, promises, gives, requests, receives, or agrees to receive bribes. Studee prohibits agents and their sub agents:

from offering, promising, giving, soliciting, or accepting any bribe. The bribe might be cash, a gift, or other inducements to, or from, any person or organization, whether a public or government official, an official of a state-controlled industry, a political party, or a private person or company, regardless of whether the employee or associated person is situated in the UK or overseas. For example, giving students cash in order to bribe them to apply to a university they will receive a commission from.
From offering, promising, giving, soliciting, or accepting indirect contributions, payments, or gifts made in any manner as an inducement or reward. For example, accepting payment as a bribe from a prospective student or parent in order to help them secure a university place.
From giving or receiving excessive gifts, entertainment, and hospitality which can be used to improperly influence. For example, receiving an excessive gift for helping support the student with the completion of their application could lead to them expecting you to falsify documents or write requested university work on behalf of the student.

This is not intended to prohibit the following practices, provided they’re appropriate, proportionate, and properly recorded:

corporate entertainment, gifts, hospitality, and promotional expenditure that is undertaken: for the purpose of establishing or maintaining good business relationships. For example:

Gifts from Studee to agents e.g. electronic tablets to counselors – the provision of small corporate gifts in a cultural context is acceptable, provided they are given without an expectation of a material return benefit.

to improve the image and reputation of the agent or their sub agent. For example:

Gifts to students to choose agency A over agency B – must be demonstrably part of a marketing campaign and proportionate to the situation.

to present the agent or their sub agents services effectively; provided that it is:
- arranged in good faith, and
- not offered, promised, or accepted to secure an advantage for the agent, their sub agent or Studee, or any of its employees or associated persons

What we’d like you to do

Record keeping can be exploited to conceal bribes or corrupt practices. The agent and their sub agencies must ensure that they have robust controls in place so that their records are accurate and transparent.

The prevention, detection, and reporting of bribery or corruption is the responsibility of everyone. Report to Studee if you think you are in breach of this or become aware or suspect something has taken place as a bribe to do with a student enrolling at a Studee partner university.

You can report a bribe to [email protected]

Disciplinary action

You may be subject to disciplinary action which may ultimately result in the termination of your agreement with us if you are in breach of this policy.