Anti-bribery & corruption policy
Studee Ltd, We value our reputation and commitment to maintaining the highest level of ethical standards. The actions and conduct of our team, as well as others acting on our behalf, is key to maintaining these standards.
We prohibit offering, giving, solicitation or acceptance of any bribe or corrupt inducement, whether in cash or in any other form:
- To or from any person or company wherever located, whether a public official or public body, or a private person or company
- By any individual employee, partner, agent, consultant, contractor or other person or body acting on our behalf
- In order to gain any commercial, contractual or regulatory advantage in any way which is unethical or to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual
This is not intended to prohibit the following practices, provided they’re appropriate, proportionate and are properly recorded:
- Appropriate levels of hospitality
- Fast tracking a process which is available to all on the payment of a fee
- Providing resources to assist a person or body to make a decision more efficiently, provided that it is for this purpose only
If you think you could be in breach of this policy or the law, speak to Simon Andrews who is our compliance officer.
We will investigate any actual or suspected breach of this policy and you may be subject to disciplinary action which may ultimately result in your dismissal.
Key risk areas
- Gifts, entertainment and hospitality are acceptable provided they are within reasonable limits.
- Excessive gifts, entertainment and hospitality can be used to improperly influence decision makers. If the value received or given is over £50 per person, you need to speak to our compliance officer.
- Facilitation payments are used by businesses or individuals to secure or expedite the performance of a routine or necessary action to which the payer has an entitlement as of right. We will not tolerate or excuse payments like this being made.
- Reciprocal agreements or any other form of ‘quid pro quo’ are never acceptable unless they are legitimate business arrangements which are properly documented and approved. Improper payments to obtain new business, retain existing business or secure any improper advantage should never be accepted or made.
- Actions by third parties for which we may be held responsible can include actions by a range of people, e.g. agents, contractors and consultants, acting on our behalf. Appropriate due diligence should be undertaken before a third party is engaged. Third parties should only be engaged where there is a clear business rationale for doing so, with an appropriate contract. Any payments to third parties should be properly authorised and recorded.
- Record keeping can be exploited to conceal bribes or corrupt practices. We must ensure that we have robust controls in place so that our records are accurate and transparent. Our compliance officer is responsible for all record keeping.
Employee responsibility and how to raise a concern
The prevention, detection and reporting of bribery or corruption is the responsibility of everyone. If you become aware or suspect something has taken place as a bribe or is corrupt, then you have a duty to report this to our compliance officer.