Bribery and anti-corruption policy

Studee takes a zero-tolerance approach to bribery and corruption. We do not offer, give, solicit, or accept bribes, kickbacks, or other improper payments - directly or through anyone acting on our behalf - and we expect the same of the people and organisations we work with.

This policy explains how we apply that commitment in practice, who it covers, and how to raise a concern if you think something has gone wrong.

Who this policy applies to

This policy applies to:

• everyone employed by Studee Ltd, including permanent, fixed-term, and part-time staff;
• contractors, agency staff, consultants, interns, and anyone else performing services for or on behalf of Studee; and
• our commercial partners - universities - to the extent set out in our contracts with them. Partners are required to acknowledge this policy as part of onboarding, and to comply with anti-bribery law in their own dealings with Studee.

If you act for Studee in any capacity, you are expected to read this policy and follow it.

The legal frame

Studee Ltd is registered in England and Wales, and our operations are governed by the UK Bribery Act 2010. The Act creates four offences relevant to us:

• bribing another person (section 1 of the UK Bribery Act 2010);
• being bribed (section 2);
• bribing a foreign public official (section 6); and
• the failure of a commercial organisation to prevent bribery by an associated person (section 7).

The section 7 offence is the one most directly relevant to how Studee operates. It makes a company liable where a person performing services for it - an "associated person" within the meaning of section 8 of the Act - pays a bribe intending to obtain or retain business, or a business advantage, for the company. The Act provides a defence where the organisation can show that it had adequate procedures in place designed to prevent bribery. This policy, together with the supporting practices described below, is the core of Studee's adequate-procedures framework.

We also have regard to the Ministry of Justice statutory guidance issued under section 9 of the UK Bribery Act 2010 (published in 2011), which sets out six principles for adequate procedures. The sections that follow are organised around those principles.

Our adequate-procedures framework

We are a small company, and we describe our procedures honestly rather than aspirationally. Where a control is in place today, we say so. Where we are still building it out, we say that too.

Proportionate procedures

Our anti-bribery controls are proportionate to the size of Studee, the nature of our business (a public content and discovery site for international study), and the partners we work with. We maintain a written policy (this document), set expectations in our partner contracts, and require staff and partners to acknowledge the policy.

Top-level commitment

Studee's directors are responsible for setting the tone on anti-bribery and for backing this policy. They have approved this policy, and they are accountable for the resourcing and oversight needed to keep it effective.

Risk assessment

We assess bribery and corruption risk in the parts of our business where it is most likely to arise. The areas we currently focus on are:

• relationships with universities and partner organisations that pay or receive fees in connection with our services; and
• gifts, hospitality, and travel offered to or by Studee staff.

Our risk assessment is reviewed when there is a material change to the business - for example, a new partner type, a new geography, or a new commercial model - and at least once during each annual review of this policy.

Due diligence on partners

Before entering a commercial relationship with a partner, we carry out proportionate due diligence. This includes basic identity and corporate-status checks, written contractual terms that include anti-bribery commitments, and acknowledgement of this policy. Higher-risk relationships receive more detailed review.

Communication and training

We make this policy available to all staff and to our partners. New joiners are pointed to it during onboarding, and we require staff in roles with greater bribery risk - for example, partnerships, sales, and finance - to confirm that they have read and understood it. We are evaluating a more structured anti-bribery training programme for FY2026.

Monitoring and review

We review this policy at least once a year, and sooner if there is a material change in our business, our risk profile, or the relevant law or guidance. The review checks that the policy still reflects how Studee operates and that the supporting practices (contract terms, due-diligence checks, acknowledgement records) are being followed in practice. Findings from concerns raised under this policy are taken into account during each review.

Specific risk areas

Facilitation payments

We do not make or accept facilitation payments - small unofficial payments made to secure or speed up a routine action by a public official. This applies regardless of local custom in the country where the payment is requested. If you are asked for one, refuse and report it using the route in "Raising a concern" below.

Gifts and hospitality

Modest, occasional, and proportionate gifts and hospitality given or received in the normal course of business are usually acceptable. Gifts and hospitality become a problem when they are lavish, frequent, given or received around the time of a commercial decision, or otherwise capable of looking like an attempt to influence a decision improperly.

If you are unsure whether a gift or hospitality is appropriate, the safe answer is to decline and check with your manager before accepting. Cash and cash-equivalent gifts (for example, gift cards or vouchers) must not be given or accepted in any amount.

Charitable and political donations

Studee may make charitable donations from time to time. Charitable donations must be made to bona fide registered charities, must not be linked - directly or indirectly - to any commercial decision involving the recipient, and must be properly recorded. Studee does not make political donations.

Third-party intermediaries

The largest section 7 risk for a company like Studee comes from the people who act for us in dealings with universities. We address this through written contracts that require partners to comply with anti-bribery law, prohibit improper payments made on Studee's behalf, and require partners to cooperate with reasonable Studee enquiries if a concern is raised. See our Terms and conditions for the broader contractual frame.

Raising a concern

If you believe that bribery or corruption has occurred, is occurring, or is being asked of you - whether by a colleague, a partner, or anyone else acting in connection with Studee - please tell us. You can raise a concern in confidence by emailing [email protected].

When you raise a concern, please include as much factual detail as you can: what happened, who was involved, when, and any documents or messages that are relevant. We will treat the report confidentially, share it only with people who genuinely need to know in order to investigate, and follow up with you on the outcome where it is appropriate to do so.

Studee will not retaliate against anyone who raises a concern in good faith under this policy, even if the concern turns out to be mistaken. Retaliation against a person who raises a concern is itself a breach of this policy and will be treated seriously. Where a concern also amounts to a qualifying disclosure under the Public Interest Disclosure Act 1998 (which inserted Part IVA into the Employment Rights Act 1996), nothing in this policy limits the statutory protections that apply to the person making the disclosure.

Review

This policy was last reviewed on 8 May 2026 and is next due for review by 8 May 2027.