Counter-fraud and anti-bribery policy

Save this PDF as:

Size: px
Start display at page:

Download "Counter-fraud and anti-bribery policy"

Transcription

1 Counter-fraud and anti-bribery policy Responsible Officer Author Ben Bennett, Business Planning & Resources Director Corporate Office Date effective from May 2012 Date last amended November 2016 Review date November

2 Contents Section Page Number Introduction... 3 Definitions... 3 Scope... 3 Policy..4 Roles and responsibilities... 5 Training..6 Disciplinary Action... 6 Further information... 7 Review...7 Related policies... 7 Appendix A. 8 2

3 Introduction 1. This document sets out the policy and procedure for dealing with and reporting allegations of fraud or bribery. 2. NICE does not tolerate fraud and bribery and will take effective measures to eliminate it as far as possible to protect its interests and ensure the proper management of public funds. 3. NICE will foster an anti-fraud culture to ensure all staff are aware of the risks of fraud and bribery and understand what is not acceptable practice. NICE will ensure all those covered by the policy are aware of their responsibilities in reporting allegations of fraud or bribery and enable them to do so confidently in accordance with this policy and the Whistleblowing Policy. 4. NICE will ensure high standards of corporate and personal conduct and apply three fundamental public service values set out in its Standards of Business Code of Conduct: Accountability Probity Openness Definitions Everything done by those who work at NICE must be able to stand the tests of parliamentary scrutiny, public judgements on property and professional codes of conduct. Absolute honesty and integrity should be exercised in dealing with NHS patients, assets, employees, suppliers, contractors and customers. The actions of NICE should be sufficiently public and transparent to promote confidence between NICE and its patients, our employees and the public. 5. Fraud - any person who dishonestly makes a false representation to make a gain for himself or another or dishonestly fails to disclose to another person, information which he is under a legal duty to disclose, or commits fraud by abuse of position, including any offence as defined in the Fraud Act Bribery - Inducement for an action which is illegal, unethical or a breach of NICE policies. Inducements can take the form of gifts, loans, fees, rewards or other advantages. This can be defined as the offering or acceptance of inducements, gifts, favours, payment or benefit-in-kind which may influence the action of any person. Bribery does not always result in a loss. The corrupt person may not benefit directly from their deeds, but they may be unreasonably using their position to give some advantage to another. It is a common law offence of bribery to bribe the holder of a public office and it is similarly an offence for the office holder to accept a bribe. Scope 7. This policy relates to all forms of fraud and bribery and provides guidance and help to anyone who may identify suspected fraud or bribery and outlines sanctions available where an offence is suspected. 3

4 8. This policy applies to NICE staff (including those on secondment to other organisations) and the following groups of people working for or on behalf of NICE. This document describes these (non-staff) groups collectively as affiliates : committee chairs and members and remunerated expert advisers non-executive directors agency workers and contractors on temporary contract or employed through an agency to work for NICE secondees (those who are seconded to NICE from other organisations) unpaid student, volunteers or placement staff 9. It will be brought to the attention of all staff and affiliates as part of the induction process. It is incumbent on all of the above to report any concerns they may have concerning fraud and bribery. Policy 10. All staff and affiliates have a responsibility to protect the assets of NICE, from fraud, theft, or bribery. 11. NICE is committed to maintaining an honest, professional and open atmosphere within the work place, in order to fulfil the objectives of NICE. In doing so it is committed to the elimination of fraud or bribery and any allegations of an offence will be rigorously investigated. In all cases appropriate action will be taken against alleged offenders, including possible criminal prosecution and the recovery of any assets lost as a result of fraud. 12. Staff and affiliates should be alert to the risk of fraud and bribery including, but not exclusively, the following: Deception or falsification of records (eg expense claims) Corruption in procurement processes Misuse of sick leave (eg working elsewhere while on sick leave) Any attempt to fraudulently influence NICE guidance decisions. 13. Staff and affiliates having reasonable suspicions of fraud should report them in accordance with the procedure in Appendix A. It is recognised that, while cases of alleged theft are usually obvious, there may initially only be a suspicion regarding potential fraud or bribery and accordingly the matter should be reported to the Business Planning and Resources Director, the chair of the NICE Audit and Risk Committee, the Head of Internal Audit, or the Department of Health s (DH) Anti-Fraud Unit as detailed in Appendix A who will ensure that the correct procedures are followed. NICE will ensure that no individual will suffer any detrimental treatment as a result of reporting reasonably held suspicions. The Public Interest Disclosure Act 1998 gives statutory protection, within defined parameters, to staff who make disclosures about a range of subjects, including fraud and bribery, which they believe to be happening within the organisation employing them. Within this context, reasonably held means suspicions other than those which are raised maliciously and are subsequently found to be groundless. 14. Unfounded or malicious allegations will be subject to a full investigation and appropriate disciplinary action in accordance with NICE policies. 4

5 15. Bribing anybody or accepting a bribe is prohibited. This means that you must not offer or receive any promise, reward in any way or give a financial or other advantage to any person in order to induce that person to perform his/her function or activities improperly. Gifts or hospitality should not be accepted in relation to the development of NICE guidance or other products and any suspicion that an offer of gifts or hospitality is being made as an attempt to influence NICE guidance decisions should be promptly reported to the Business Planning and Resources Director or the chair of the NICE Audit and Risk Committee. Gifts and hospitality must not be accepted except as permitted under the NICE Gifts and Hospitality policy. 16. NICE procures goods and services ethically and transparently with the quality, price and value for money determining the successful supplier/contractor, not by receiving (or offering) improper benefits. NICE will not engage in any form of bribery in its procurement processes. 17. NICE may, in certain circumstances, be held responsible for acts of bribery committed by intermediaries acting on its behalf such as subsidiaries, clients, contractors, suppliers, agents, advisors, consultants or other third parties. The use of intermediaries for the purpose of committing acts of bribery is prohibited. 18. NICE will contractually require its agents and other intermediaries to comply with the Anti-Bribery Act 2010 and to keep proper books and records available for inspection by NICE or investigating authorities to enable Counter-Fraud and Anti-Corruption activities. Roles and responsibilities Chief Executive 19. The Chief Executive of NICE is liable to be called to account for specific failures in the NICE system of internal controls. However, responsibility for the operation and maintenance of controls falls directly to line managers and requires the involvement of all of NICE staff. Staff and affiliates 20. All staff and affiliates should be aware that fraud and bribery will normally, dependent upon the circumstances of the case, be regarded as gross misconduct which may result in dismissal. However, no such action will be taken before a proper investigation and a disciplinary hearing have taken place in accordance with NICE policies. Such actions may be in addition to the possibility of criminal prosecution. 21. Staff and affiliates will not request or receive a bribe from anybody, nor imply that such an act might be considered. This means that you will not agree to receive or accept a financial or other advantage from a former, current or future client, business partner, contractor or supplier or any other person as an incentive or reward to perform improperly your function or activities. 22. Staff and affiliates must act in accordance with the NICE Standards of Business Code of Conduct, Gifts and Hospitality and Conflicts of Interest policies which include guidance on the receipt of gifts or hospitality. 23. When a staff member or affiliate suspects that there has been fraud or bribery, they must report the matter to their line manager, the Business Planning and Resources Director or the chair of the NICE Audit and Risk Committee or directly to the DH Anti- Fraud Unit. 5

6 24. NICE wants all staff and affiliates to feel confident that they can expose any wrongdoing without any risk to themselves. In accordance with the provisions of the Public Interest Disclosure Act 1998, NICE has produced a whistleblowing policy. This procedure is intended to complement the NICE Anti-Fraud and Bribery Policy and code of business conduct and ensures there is full provision for staff to raise any concerns with others if they do not feel able to raise them with their line manager / management chain. Suspected fraud against the Department of Health and its Arms Length Bodies can also be reported anonymously through the NHS Fraud and Corruption Reporting Line or through NHS Protect s online form at Line managers 25. Line managers at all levels have a responsibility to ensure that an adequate system of internal control exists within their areas of responsibility and that those controls operate effectively. The responsibility for the prevention and detection of fraud and bribery therefore primarily rests with line managers. Business planning and resources director 26. The Business Planning and Resources Director, in consultation with the Chair of the Audit and Risk Committee or DH Anti-Fraud Unit as appropriate will decide whether there is sufficient cause to conduct an investigation, and whether the Police and External Audit need to be informed. He/she will ensure any losses arising from the fraud are recovered with decisions taken on a case by cases basis. DH Anti-Fraud Unit 27. Investigation of the majority cases of alleged fraud within NICE will be the responsibility of the DH Anti-Fraud Unit (AFU). The AFU is named in the current Regulation of Investigatory Powers Act (RIPA) bill, giving it additional powers to investigate cases and seek recovery of any monies lost. Chair of the audit and risk committee 28. The chair of the Audit and Risk Committee will be consulted on all serious cases of fraudulent activity and periodically commission reports from Internal Auditors to ensure the committee can receive assurance, on behalf of the Board, that counter fraud and anti-bribery controls at NICE remain robust with appropriate management oversight. Training 29. NICE will provide anti-bribery training to all relevant staff and affiliates and make them aware of our Anti-Fraud and Bribery Policy, including possible types of bribery, the risks of engaging in bribery activity, and how employees may report suspicion of bribery. This training may be provided by the DH Anti-Fraud Unit. Disciplinary Action 30. NICE disciplinary procedures may be applied where an employee is suspected of being involved in a fraudulent or other illegal act. 31. It should be noted, however, that the duty to follow disciplinary procedures will not override the need for legal action to be taken (e.g. consideration of criminal action). In the event of doubt, legal statute shall prevail. 6

7 Further information 32. Legislation relating to fraud and bribery is complex. If anyone has any concerns about the interpretation of the Acts they should contact the Business Planning and Resources Director or the chair of the NICE Audit and Risk Committee or the Head of Internal Audit as detailed in Appendix A for advice. 33. NICE may be required to report details of frauds to its sponsoring Department and to HM Treasury from time to time. This allows departments and agencies to learn from the experiences of others when reviewing and developing their own systems. It also aims to increase awareness of fraud risk in specific areas and suggests ways in which the risk can be managed and reduced. Review 34. This policy will be monitored by the Corporate Office and reviewed every 3 years. Related policies Whistleblowing Policy Standards of Business Code of Conduct Disciplinary Policy and Procedure Conflicts of Interest Policy Gifts and Hospitality Policy 7

8 Appendix A National Institute for Health and Care Excellence ACTION TO BE TAKEN IF YOU DISCOVER OR SUSPECT ANY FRAUDULENT ACTIVITY! This includes: Fraud Any deliberate intention to make a gain for themselves or anyone else, or inflicting a loss (or a risk of loss) on another.this could be through the falsification of any records or documents or obtaining any service(s) and/or failing to disclose information. Bribery Anything that induces or intends to induce improper performance. This covers offering, promising or giving a bribe, requesting, agreeing to receive or accepting a bribe, and failing to prevent bribery. Where someone is influenced by bribery, payment of benefit-in-kind to unreasonably use their position to give some advantage to another. What to do: If any of these concerns come to light you must immediately report your suspicions and what you have discovered to one of the following: 1. Your line manager 2. Ben Bennett, Business Planning and Resources Director 3. Jonathan Tross, Non- Executive Director and Chair of the Audit and Risk Committee 4. DH Anti-Fraud Unit, Pat Nolan or by k). 5. NHS Fraud and Corruption reporting line or NHS Protect s online form at They will liaise as necessary with: The Head of Internal Audit Jeremy Nolan, / / ) Patrick Nolan Investigations Manager DH Anti-Fraud Unit, Room GS02, Department of Health, Wellington House, Waterloo Road, London, SE1 8UG or Confidentiality will be maintained and all matters will be dealt with. You will not suffer any recriminations as a result of raising concerns You have protection under The Public Interest Disclosure Act Tell someone! DO Confidentiality will be respected. Any delay might cause the organisation to suffer further financial loss. Make a note of your concerns! Note all relevant details, what was said, the date time and names of all parties involved. Keep a record or copy any documentation that arouses your suspicion. DO NOT Confront the individual(s) with your suspicions. Try to investigate the matter yourself. Contact the police directly. Convey your suspicions to anyone other than those with the proper authority as listed. Discuss suspicions, case facts or the investigation with anyone unless advised otherwise by the AFU, and this includes colleagues in and outside of NICE. Do nothing! 8

9 Appendix B - Version Control Sheet Version Date Author Replaces Comment 2 October November 2016 Corporate Office Corporate Office Counter Fraud and Anti-Bribery Policy May 2012 Counter Fraud and Anti-Bribery Policy October 2013 Amended to reflect role of the DH AFU and to reference NHS Fraud and Corruption Reporting Line 9

Anti-Fraud, Bribery and Corruption Response Policy. Telford and Wrekin Clinical Commissioning Group

Anti-Fraud, Bribery and Corruption Response Policy. Telford and Wrekin Clinical Commissioning Group Anti-Fraud, Bribery and Corruption Response Policy 2018 Telford and Wrekin Clinical Commissioning Group The Anti-Fraud, Bribery and Corruption Policy for Telford and Wrekin Clinical Commissioning Group

More information

The LTE Group. Anti-Bribery Policy Produced by. The LTE Group. LTEG anti-bribery policy v4 06/2016

The LTE Group. Anti-Bribery Policy Produced by. The LTE Group. LTEG anti-bribery policy v4 06/2016 The LTE Group Produced by The LTE Group LTEG anti-bribery policy v4 06/2016 All rights reserved; no part of this publication may be photocopied, recorded or otherwise reproduced, stored in a retrieval

More information

Anti-Bribery Policy WHC reserves the right to amend this policy at its discretion. The most up-to-date version can be downloaded from our website.

Anti-Bribery Policy WHC reserves the right to amend this policy at its discretion. The most up-to-date version can be downloaded from our website. ANTI-BRIBERY POLICY ELT manager Director of Finance Responsible officer Director of Finance Date first approved by BoM 29 th March 2012 Date review approved by BoM 4 th October 2017 Next Review Date October

More information

Anti-Bribery Policy. November 2018

Anti-Bribery Policy. November 2018 Anti-Bribery Policy November 2018 UCPS Anti-Bribery Policy Review Frequency Two years Review date November 2020 Governing Committee Responsible Finance Resources and Buildings Governor Approval (date)

More information

ANTI FRAUD, BRIBERY AND CORRUPTION POLICY

ANTI FRAUD, BRIBERY AND CORRUPTION POLICY ANTI FRAUD, BRIBERY AND CORRUPTION POLICY Version: 2.0 Ratified by: NHS Leeds West CCG Audit Committee Date ratified: 9 December 2015 Name & Title of Originator/Author(s): Visseh Pejhan-Sykes, Chief Finance

More information

Anti-Fraud, Bribery and Corruption Policy

Anti-Fraud, Bribery and Corruption Policy Anti-Fraud, Bribery and Corruption Policy Anti-Fraud, Bribery and Corruption Policy Version 2 Approved by: Audit and Risk Committee Approved date: 22 May 2017 1.0 Introduction 1.1 Optivo is committed to

More information

Anti-Fraud, Bribery and Corruption Policy and Response Plan

Anti-Fraud, Bribery and Corruption Policy and Response Plan Anti-Fraud, Bribery and Corruption Policy and Response Plan Ref: Finance 2.1 Version: 3.0 Supersedes: Author (inc Job Title): Ratified by: (Name of responsible Committee) 2.1 Anti-Bribery Policy and Procedure

More information

3.1 A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

3.1 A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. ANTI-BRIBERY POLICY Last review October 2016 Next review October 2018 It is Canoe Wales policy to conduct all of our business in an honest and ethical manner. Canoe Wales takes a zero-tolerance approach

More information

Policy on the Prevention of Bribery and Corruption

Policy on the Prevention of Bribery and Corruption UNIVERSITY OF LEICESTER Policy on the Prevention of Bribery and Corruption This University Policy on the Prevention of Bribery and Corruption has been adopted and endorsed by Council, the University s

More information

Anti-Bribery Policy. Anti-Bribery Policy

Anti-Bribery Policy. Anti-Bribery Policy 1. Introduction 1.1 It is ASET s policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally,

More information

ANTI-CORRUPTION AND BRIBERY POLICY

ANTI-CORRUPTION AND BRIBERY POLICY ANTI-CORRUPTION AND BRIBERY POLICY Date Approved by Governors March 2017 Review Date March 2019 On behalf of Governors signed Print name On behalf of Governors signed Print name Principal s signature All

More information

GAC Anti-Corruption & Bribery Policy. January 2018

GAC Anti-Corruption & Bribery Policy. January 2018 GAC Anti-Corruption & Bribery Policy January 2018 1.1 This Anti-Corruption and Bribery policy complements the GAC Code of Ethics. The GAC Code of Ethics emphasises that the values promoted in the Code

More information

ANTI-BRIBERY AND CORRUPTION POLICY Version 3 January 2018)

ANTI-BRIBERY AND CORRUPTION POLICY Version 3 January 2018) ANTI-BRIBERY AND CORRUPTION POLICY Version 3 January 2018) Applicable to (Group/company/specific groups of staff /third parties) Produced by (Name/s and job title/s) All Group Companies and Staff R. Deards

More information

GAC Anti-Corruption and Bribery Policy. November 2015

GAC Anti-Corruption and Bribery Policy. November 2015 November 2015 1. POLICY STATEMENT 1.1 This Anti-Corruption and Bribery policy complements the GAC Code of Ethics. The GAC Code of Ethics emphasises that the values promoted in the Code must underlie all

More information

ANTI-CORRUPTION AND BRIBERY POLICY

ANTI-CORRUPTION AND BRIBERY POLICY Issue 2 Date: June 2017 Page 1 ANTI-CORRUPTION AND BRIBERY POLICY This policy is endorsed by Harworth s Board of Directors and will be reviewed regularly. This policy may be changed from time to time and

More information

Anti-Corruption and Bribery Policy

Anti-Corruption and Bribery Policy 1. POLICY STATEMENT 1.1 It is our policy to conduct all of our business in an honest and ethical manner. We take a zerotolerance approach to bribery and corruption and are committed to acting professionally,

More information

ANTI-BRIBERY POLICY. 1. Purpose

ANTI-BRIBERY POLICY. 1. Purpose ANTI-BRIBERY POLICY 1. Purpose The purpose of this policy is to establish controls to ensure compliance with all applicable anti-bribery and corruption regulations, and to ensure that the Company s business

More information

NORTHERN IRELAND SOCIAL CARE COUNCIL

NORTHERN IRELAND SOCIAL CARE COUNCIL NORTHERN IRELAND SOCIAL CARE COUNCIL BRIBERY POLICY FINAL SEPTMBER 2012 1. INTRODUCTION The Bribery Act 2010 (the Act) introduces a new, clearer regime for tackling bribery that applies to all commercial

More information

St Michael s Prep School Anti-bribery and corruption policy

St Michael s Prep School Anti-bribery and corruption policy St Michael s Prep School Anti-bribery and corruption policy Date of Last Review: 31.08.16 Review Period: Every 2 years Date of Next Review: 31.08.18 Owner: DBI Type of Policy: Compliance with Bribery Act

More information

REF: Legal & Resources Recommended Policy. APPROVAL BODY: DATE: July 2016 REVIEW DATE: July 2019

REF: Legal & Resources Recommended Policy. APPROVAL BODY: DATE: July 2016 REVIEW DATE: July 2019 POLICY: ANTI-BRIBERY & CORRUPTION REF: Legal & Resources Recommended Policy VERSION: 1 APPROVAL BODY: DATE: July 2016 REVIEW DATE: July 2019 LEAD PERSON/ COMPLIANCE OFFICER: VERSION REVIEWER/ APPROVAL

More information

Malaria Consortium Anti-Bribery Policy

Malaria Consortium Anti-Bribery Policy Malaria Consortium Anti-Bribery Policy Last updated: October 2018 Author: Finance Director Review date: October 2020 Anti-bribery policy, September 2018 Page 1 1. Purpose and context This policy applies

More information

FIA INSTITUTE ANTI BRIBERY AND CORRUPTION POLICY

FIA INSTITUTE ANTI BRIBERY AND CORRUPTION POLICY ! FIA INSTITUTE ANTI BRIBERY AND CORRUPTION POLICY 1. POLICY STATEMENT 1.1 As indicated in Article 8 of the Internal Regulations of the FIA Institute, we take a zero tolerance approach to bribery and corruption

More information

Anti-corruption and bribery policy.

Anti-corruption and bribery policy. Anti-corruption and bribery policy. 1. Policy statement 1.1 It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption

More information

Anti Bribery Policy. 1.2 We will uphold all laws relevant to countering bribery and corruption, including the Bribery Act 2010.

Anti Bribery Policy. 1.2 We will uphold all laws relevant to countering bribery and corruption, including the Bribery Act 2010. Anti Bribery Policy 1. Policy statement 1.1 It is our policy to conduct all of our business in an honest and ethical manner. We take a zerotolerance approach to bribery and corruption and are committed

More information

Anti-bribery Policy. Approving Body: Council. Date of Approval: 26 November Policy owner: Director of Finance and Corporate Services

Anti-bribery Policy. Approving Body: Council. Date of Approval: 26 November Policy owner: Director of Finance and Corporate Services Anti-bribery Policy Approving Body: Council Date of Approval: 26 November 2018 Policy owner: Director of Finance and Corporate Services Policy contact: Stephen Forster, stf17@aber.ac.uk Policy status:

More information

Simply Media TV Limited: Anti-corruption and bribery policy. DATED JUNE 2013 ANTI-CORRUPTION AND BRIBERY POLICY

Simply Media TV Limited: Anti-corruption and bribery policy. DATED JUNE 2013 ANTI-CORRUPTION AND BRIBERY POLICY Simply Media TV Limited: Anti-corruption and bribery policy. DATED JUNE 2013 ANTI-CORRUPTION AND BRIBERY POLICY CONTENTS CLAUSE 1. Policy statement... 1 2. Who must comply with this policy?... 1 3. What

More information

Anti-Corruption & Bribery Policy (including gifts and hospitality)

Anti-Corruption & Bribery Policy (including gifts and hospitality) Anti-Corruption & Bribery Policy (including gifts and hospitality) Academy Transformation Trust Further Education (ATT FE) Policy adopted by FE Board 4 th November 2015 This policy links to: Whistle Blowing

More information

SCOTTISH JUNIOR FOOTBALL ASSOCIATION ANTI-CORRUPTION AND BRIBERY POLICY

SCOTTISH JUNIOR FOOTBALL ASSOCIATION ANTI-CORRUPTION AND BRIBERY POLICY SCOTTISH JUNIOR FOOTBALL ASSOCIATION ANTI-CORRUPTION AND BRIBERY POLICY ANTI-CORRUPTION AND BRIBERY POLICY CONTENTS CLAUSE 1. Policy statement 3 2. About this policy 3 3. Who must comply with this policy?

More information

UNIVERSITY OF ROEHAMPTON ANTI-CORRUPTION & BRIBERY POLICY

UNIVERSITY OF ROEHAMPTON ANTI-CORRUPTION & BRIBERY POLICY UNIVERSITY OF ROEHAMPTON ANTI-CORRUPTION & BRIBERY POLICY Originated by Legal Officer: May 2014 Recommended by Nominations & Governance Committee 2 March 2015 Endorsed by Senate: 18 June 2014 Approved

More information

Director of Customer Care & Performance. 26 April The Board is asked to consider and approve the attached draft

Director of Customer Care & Performance. 26 April The Board is asked to consider and approve the attached draft To: From: Subject: Status: Date of Meeting: BSO Board Director of Customer Care & Performance Anti Bribery Policy For Approval 26 April 2012 The Board is asked to consider and approve the attached draft

More information

ANTI-CORRUPTION & BRIBERY

ANTI-CORRUPTION & BRIBERY Page 1 of 11 ANTI-CORRUPTION & BRIBERY Page 2 of 11 CONTENTS CLAUSE 1. Policy statement... 3 2. Who is covered by the policy?... 4 3. What is bribery?... 4 4. Gifts and hospitality... 5 5. What is not

More information

1.3 The required standards of integrity confer a level of personal responsibility upon individuals. This Policy thus applies to:

1.3 The required standards of integrity confer a level of personal responsibility upon individuals. This Policy thus applies to: ANTI-BRIBERY POLICY 1. Introduction 1.1 The University has an absolute commitment to acting ethically, lawfully and with integrity in all its dealings, wherever it operates in the world. As part of this

More information

Anti-Bribery Policy. Policies, Guidance & Procedures. The Collett School, St Luke s School Forest House Education Centre

Anti-Bribery Policy. Policies, Guidance & Procedures. The Collett School, St Luke s School Forest House Education Centre The Collett School, St Luke s School Forest House Education Centre Policies, Guidance & Procedures Anti-Bribery Policy Date established: September 2015 Reviewed: August 2017 Date for review: September

More information

GLOBAL NEW CAR ASSESSMENT PORGRAMME ANTI BRIBERY AND CORRUPTION POLICY [DRAFT]

GLOBAL NEW CAR ASSESSMENT PORGRAMME ANTI BRIBERY AND CORRUPTION POLICY [DRAFT] GLOBAL NEW CAR ASSESSMENT PORGRAMME ANTI BRIBERY AND CORRUPTION POLICY [DRAFT] 1. POLICY STATEMENT 1.1 We take a zero tolerance approach to bribery and corruption and will uphold all laws relevant to countering

More information

Little Rascals Pre-school Anti-Bribery Policy

Little Rascals Pre-school Anti-Bribery Policy Little Rascals Pre-school Anti-Bribery Policy Purpose The purpose of this policy is to establish controls to ensure compliance with all applicable antibribery and corruption regulations, and to ensure

More information

ANTI-BRIBERY POLICY AND PROCEDURES

ANTI-BRIBERY POLICY AND PROCEDURES ANTI-BRIBERY POLICY AND PROCEDURES For use by: All Society employees; Members undertaking activities on behalf of the Society; agents, consultants and contractors acting for the Society. Owner Director

More information

Whistleblowing Policy

Whistleblowing Policy Whistleblowing Policy 1. Introduction 1.1 The University of Bristol is committed to maintaining the highest standards of honesty openness and accountability and to conducting its business in a responsible

More information

Zen Internet ANTI-CORRUPTION AND BRIBERY POLICY. Zen Legal Department. Issue: v.2.final. Date: Wednesday, 05 August 2015

Zen Internet ANTI-CORRUPTION AND BRIBERY POLICY. Zen Legal Department. Issue: v.2.final. Date: Wednesday, 05 August 2015 Zen Internet Zen Legal Department Issue: v.2.final Date: Wednesday, 05 August 2015 Contents 1 Policy Statement...1 2 About this policy...2 3 Who must comply with this policy?...3 4 Who is responsible for

More information

ANTI-BRIBERY & CORRUPTION POLICY

ANTI-BRIBERY & CORRUPTION POLICY GABRIEL RESOURCES LIMITED ANTI-BRIBERY & CORRUPTION POLICY 1 INTRODUCTION 1.1 The Board of Directors of Gabriel Resources Ltd. 1 (the Company or "Gabriel") has determined that, on the recommendation of

More information

ANTI BRIBERY AND CORRUPTION POLICY

ANTI BRIBERY AND CORRUPTION POLICY ANTI BRIBERY AND CORRUPTION POLICY 1. POLICY STATEMENT 1.1 The Foundation takes a zero tolerance approach to bribery and corruption and will uphold all applicable laws relevant to countering bribery and

More information

YMCA NSW Whistle Blower Policy

YMCA NSW Whistle Blower Policy 1. Document control Overview A whistle-blower is any employee, volunteer, contractor or people associated with the YMCA NSW that detects wrongdoing, or has reasonable grounds for suspecting wrongdoing

More information

Anti-Corruption Policy

Anti-Corruption Policy Anti-Corruption Policy Version: 1 Page 1 of 10 INTRODUCTION 1 Our Commitment Accolade Wines conducts all of its business in an honest and ethical manner. We take a zero-tolerance approach to bribery and

More information

ANTI-BRIBERY AND CORRUPTION POLICY UK ENGINEERING RECRUITMENT LTD

ANTI-BRIBERY AND CORRUPTION POLICY UK ENGINEERING RECRUITMENT LTD Page 1 of 5 Contents: ANTI-BRIBERY AND CORRUPTION POLICY 1. Definitions 2. Introduction 3. Purpose and scope of this policy 4. The Bribery Act 2010 5. The risks of not acting with integrity 6. The benefits

More information

CCG CO06: Anti-Fraud, Bribery and Corruption Policy

CCG CO06: Anti-Fraud, Bribery and Corruption Policy Corporate CCG CO06: Anti-Fraud, Bribery and Corruption Policy Version Number Date Issued Review Date V2 17/03/2016 01/09/2016 Prepared By: Consultation Process: Formally Approved: Policy Adopted From:

More information

NORTHERN IRELAND PRACTICE AND EDUCATION COUNCIL FOR NURSING AND MIDWIFERY

NORTHERN IRELAND PRACTICE AND EDUCATION COUNCIL FOR NURSING AND MIDWIFERY NIPEC/12/12 NORTHERN IRELAND PRACTICE AND EDUCATION COUNCIL FOR NURSING AND MIDWIFERY Anti-Bribery Policy May 2012 Review date: April 2015 Centre House 79 Chichester Street BELFAST BT1 4JE Tel: (028) 9023

More information

POLICY - COMPLIANCE. Public Interest Disclosure Policy

POLICY - COMPLIANCE. Public Interest Disclosure Policy 1. Policy Statement Hinchinbrook Shire Council ( Council ) is committed to the promotion of the public interest and encourages and supports Public Interest Disclosures ( PIDs ) of wrong doing in Council.

More information

[company name] Anti-Bribery & Anti-Corruption Policy

[company name] Anti-Bribery & Anti-Corruption Policy [company name] Anti-Bribery & Anti-Corruption Policy Contents 1. What does your policy cover?...3 2. Policy statement...3 3. Who is covered by the policy?... 3-4 4.. Definition of bribery...4 5.. What

More information

Procurement. Anti Bribery Policy

Procurement. Anti Bribery Policy Procurement Anti Bribery Policy Policy Manager Andy Hay Policy Group Procurement Policy Established March 2014 Policy Review Period/Expiry Last Updated March 2014 This policy does / does not apply to Medical/Dental

More information

Furness Building Society. Bribery Policy

Furness Building Society. Bribery Policy Furness Building Society Bribery Policy 1. Objectives 1.1 The aim of the Furness Building Society s Bribery Policy ( Bribery Policy ) is to set out our practice and approach for countering bribery. 1.2

More information

It is the responsibility of all Fletcher Personnel to understand and comply with this Policy, including any reporting requirements set out below.

It is the responsibility of all Fletcher Personnel to understand and comply with this Policy, including any reporting requirements set out below. POLICY: ANTI-BRIBERY AND CORRUPTION 1. POLICY STATEMENT AND PURPOSE Fletcher Building Limited ( Fletcher Building ) is committed to complying with the law in all jurisdictions in which we operate, as well

More information

ANTI-CORRUPTION AND BRIBERY POLICY - INCLUDING CODE OF PRACTICE ON BUSINESS GIFTS AND HOSPITALITY

ANTI-CORRUPTION AND BRIBERY POLICY - INCLUDING CODE OF PRACTICE ON BUSINESS GIFTS AND HOSPITALITY ANTI-CORRUPTION AND BRIBERY POLICY - INCLUDING CODE OF PRACTICE ON BUSINESS GIFTS AND HOSPITALITY Policy Number 5 July 2015 This Document is for the use of Scotmid Employees and their advisors only. No

More information

ANTI-BRIBERY POLICY 1 POLICY STATEMENT

ANTI-BRIBERY POLICY 1 POLICY STATEMENT ANTI-BRIBERY POLICY Issued/approved by: Modern Water plc Board on 14 June 2011 Last updated: 17 September 2014 Applies to: Modern Water plc and any company or other entity (registered or operating anywhere

More information

Bartington Instruments Ltd. Anti-Bribery Manual. The copyright of this document is the property of Bartington Instruments Ltd.

Bartington Instruments Ltd. Anti-Bribery Manual. The copyright of this document is the property of Bartington Instruments Ltd. Anti-Bribery Manual The copyright of this document is the property of Bartington Instruments Ltd. DCN 1109 DO0067 Issue 2 Page 1 of 10 Contents 1. Introduction to this manual... 3 2. Who is covered by

More information

Anti-Bribery and Corruption Policy

Anti-Bribery and Corruption Policy Anti-Bribery and Corruption Policy CONTENTS CLAUSE 1. Policy statement... 1 2. Who is covered by the policy?... 1 3. What is bribery?... 2 4. Gifts and hospitality... 2 5. What is not acceptable?... 3

More information

College Policy SUBJECT: NUMBER: 6.4. Anti-Fraud and Theft Policy ORIGINAL DATE OF ISSUE: 12/16/09 REVISED: Purpose

College Policy SUBJECT: NUMBER: 6.4. Anti-Fraud and Theft Policy ORIGINAL DATE OF ISSUE: 12/16/09 REVISED: Purpose College Policy SUBJECT: Anti-Fraud and Theft Policy NUMBER: ORIGINAL DATE OF ISSUE: REVISED: 6.4 12/16/09 Purpose Delaware County Community College is and wishes to be seen by all as being honest and opposed

More information

2. Anti-Bribery and Corruption Policy

2. Anti-Bribery and Corruption Policy 2. Anti-Bribery and Corruption Policy This document sets out the policy of Canary Wharf Group plc and its group of companies (the Group ) in relation to bribery and corruption. It may be amended by the

More information

This Policy sets out Sewtec s position on any form of bribery and corruption and provides guidelines aimed at:

This Policy sets out Sewtec s position on any form of bribery and corruption and provides guidelines aimed at: ANTI-BRIBERY & CORRUPTION POLICY Introduction Sewtec Automation Limited ( The Company ) is committed to promoting and maintaining the highest level of ethical standards in relation to all of its business

More information

Anti-Bribery Policy. Perform Green. Perform Green Limited. Registered organisation number:

Anti-Bribery Policy. Perform Green. Perform Green Limited. Registered organisation number: Anti-Bribery Policy Perform Green Anti-Bribery Policy Page 2 Table of Contents Anti-Bribery & Anti-Corruption Policy... 3 1. Policy statement... 3 2. Who is covered by the policy?... 3 3. Definition of

More information

Anti- Bribery Policy. Date of Approval: 4 th February 2014 Date for Next Scheduled Review: February 2017 Review Body:

Anti- Bribery Policy. Date of Approval: 4 th February 2014 Date for Next Scheduled Review: February 2017 Review Body: Anti-Bribery Policy Policy Title: Anti- Bribery Policy Policy Author: Kenny Stocks Date of Approval: 4 th February 2014 Date for Next Scheduled Review: February 2017 Review Body: MC Equality Impact Assessment

More information

AIDENVIRONMENT ANTI-CORRUPTION AND BRIBERY POLICY

AIDENVIRONMENT ANTI-CORRUPTION AND BRIBERY POLICY AIDENVIRONMENT ANTI-CORRUPTION AND BRIBERY POLICY CONTENTS CLAUSE 1. Policy statement... 3 2. Who is covered by the policy?... 4 3. What is bribery?... 4 4. Hospitality and gifts... 5 5. What is not acceptable?...

More information

COUNCIL POLICY BACKGROUND

COUNCIL POLICY BACKGROUND Policy Title: Whistle-blower Policy Policy Number: CC026 Report Number: AC2007-26 Approved by: Council Effective Date: 2007 May 28 Business Unit: City Auditor s Office BACKGROUND The Corporation of The

More information

Anti-bribery policy. Jesuit Provincial Offices 114 Mount Street London W1K 3AH Index

Anti-bribery policy. Jesuit Provincial Offices 114 Mount Street London W1K 3AH Index Jesuit Provincial Offices 114 Mount Street London W1K 3AH 020 7499 0285 www.jesuit.org.uk Anti-bribery policy Index 1. Purpose of the policy 2. Overall approach 3. Policy statements 4. Scope of the policy

More information

Anti-Bribery and Corruption Policy

Anti-Bribery and Corruption Policy Anti-Bribery and Corruption Policy 1. Policy Statement In accordance with the highest standards of professional practice and good governance, the University does not tolerate bribery or corruption of any

More information

ANTI-BRIBERY POLICY. (Covering all employees) Contents

ANTI-BRIBERY POLICY. (Covering all employees) Contents ANTI-BRIBERY POLICY (Covering all employees) Contents 1. Introduction 2. Scope 3. Compliance 4. What is Bribery? 5. What is HITRANS Position on Bribery? 6. Preventing Bribery Adequate Procedures 7. Employee

More information

Risk First Anti-Corruption and Bribery Policy

Risk First Anti-Corruption and Bribery Policy Risk First Anti-Corruption and Bribery Policy Policy Owner Executive Leadership Team (ELT) Administrator General Counsel Latest Approval April 2017 Next review February 2018 Document History See final

More information

TSB CONSTRUCTIONS LTD

TSB CONSTRUCTIONS LTD BRIBERY PREVENTION 86 Stockwell Road Handsworth Birmingham, B21 9RJ West Midlands www.tsbconstructionsltd.tsbpvtltd.com constructions@tsbpvtltd.com Management System ANTI-CORRUPTION POLICY STATEMENT As

More information

ANTI-CORRUPTION & BRIBERY POLICY

ANTI-CORRUPTION & BRIBERY POLICY ANTI-CORRUPTION & BRIBERY POLICY REVISION HISTORY: ISSUE CHANGES DATE 1 Initial Issue 30/07/2015 2 General updates 09/03/2016 AUTHORISED BY: NAME TITLE SIGNATURE DATE Deon van Aswegen Quality Manager 09/03/2016

More information

POLICY: ANTI-CORRUPTION & ANTI-BRIBERY. Objective. Scope & Applicability. Definitions / Abbreviations. Content. What is bribery?

POLICY: ANTI-CORRUPTION & ANTI-BRIBERY. Objective. Scope & Applicability. Definitions / Abbreviations. Content. What is bribery? POLICY: ANTI-CORRUPTION & ANTI-BRIBERY Objective The objective of this policy is to: set out our responsibilities, and of those working for us, in observing and upholding our position on bribery and corruption

More information

ANTI BRIBERY POLICY. The University s commitment to honest and ethical trading

ANTI BRIBERY POLICY. The University s commitment to honest and ethical trading ANTI BRIBERY POLICY Introduction The Bribery Act 2010 ( Act ) came into force on 1 st July 2011, replacing a number of older laws and creating a single comprehensive code in relation to bribery. The Act

More information

Truform Manufacturing LLC. Anti-Bribery, Anti-Corruption & Rev /22/17

Truform Manufacturing LLC. Anti-Bribery, Anti-Corruption & Rev /22/17 Truform Manufacturing LLC Anti-Bribery, Anti-Corruption & Whistle Blowing Policy Contents 1. What does your policy cover?... 3 2. Policy statement... 3 3. Who is covered by the policy?... 3-4 4. Definition

More information

The Bribery Act Southampton Solent University Key Guidance (May 2017)

The Bribery Act Southampton Solent University Key Guidance (May 2017) The Bribery Act 2010 Southampton Solent University Key Guidance (May 2017) Bribery is a criminal offence in the UK and in most countries in which the University operates and from which our students come.

More information

Group Business Integrity Policy

Group Business Integrity Policy Group Business Integrity Introduction Regrettably, bribery and corruption is a feature of corporate and public life in many countries across the world. Even the suggestion of corruption may damage the

More information

The offering, giving, soliciting or acceptance of an inducement or reward which may influence the action of any person.

The offering, giving, soliciting or acceptance of an inducement or reward which may influence the action of any person. Anti-Bribery Policy Responsible Officer Director of Finance 1.0 WHAT IS BRIBERY Bribery can be defined as: The offer or receipt of any gift, loan, payment, reward or other advantage to or from any person

More information

Whistle Blowing Policy

Whistle Blowing Policy Great Bedwyn CE VC Primary School Whistle Blowing Policy Date of Last Review: November 2015 Date to be Reviewed: Will stand until LA changes apply Review Body: Full Governing Body 1 Whistle Blowing Policy

More information

POLICY AGAINST BRIBERY AND CORRUPTION. Introductory Guidance. This policy has been introduced in response to the Bribery Act 2010 ( the Act )

POLICY AGAINST BRIBERY AND CORRUPTION. Introductory Guidance. This policy has been introduced in response to the Bribery Act 2010 ( the Act ) POLICY AGAINST BRIBERY AND CORRUPTION Introductory Guidance This policy has been introduced in response to the Bribery Act 2010 ( the Act ) The Act creates four key offences:- Active bribery (the offence

More information

6.23 Anti-Bribery Policy

6.23 Anti-Bribery Policy 6.23 Anti-Bribery Policy Message from the General Director At BMS World Mission we are committed to doing the right thing, the right way. This is more important than ever because of the strict new rules

More information

Anti-Bribery & Anti-Corruption Policy

Anti-Bribery & Anti-Corruption Policy Anti-Bribery & Anti-Corruption Policy Table of Contents Anti-Bribery & Anti-Corruption Policy... 1 1. What does your policy cover?... 2 2. Policy Statement... 2 3. Who is covered by the policy?... 2 4.

More information

Policy Summary. Overview Why is the policy required? Awareness and legal compliance with Bribery Act is required to minimise risk to UHI and its staff

Policy Summary. Overview Why is the policy required? Awareness and legal compliance with Bribery Act is required to minimise risk to UHI and its staff Policy Summary Overview Why is the policy required? Purpose What will it achieve? Scope Who does it apply too? Consultation/notification Highlight plans/dates Implementation and monitoring (including costs)

More information

HYDRATIGHT GROUP ANTI-BRIBERY AND ANTI- CORRUPTION POLICY 11 MAY 2016

HYDRATIGHT GROUP ANTI-BRIBERY AND ANTI- CORRUPTION POLICY 11 MAY 2016 HYDRATIGHT GROUP ANTI-BRIBERY AND ANTI- CORRUPTION POLICY 11 MAY 2016 CONTENTS SECTION 1. Our commitment to ethical performance... 1 2. Who is covered by the policy?... 2 3. What is bribery?... 2 4. Gifts

More information

Policy/Procedure WORKING WITH INTEGRITY

Policy/Procedure WORKING WITH INTEGRITY Reference Policy/Procedure Version No. Date January 2014 Page 0 of 8 WORKING WITH INTEGRITY Briefing Note on the Anti-Corruption and Bribery Programme Status Owner Checked Approved CADOGAN PETROLEUM PLC

More information

BRIBERY AND PROCUREMENT POLICY BUCKSBURN STONEYWOOD PARISH CHURCH OF SCOTLAND SC017404

BRIBERY AND PROCUREMENT POLICY BUCKSBURN STONEYWOOD PARISH CHURCH OF SCOTLAND SC017404 BRIBERY AND PROCUREMENT POLICY OF BUCKSBURN STONEYWOOD PARISH CHURCH OF SCOTLAND SC07404 Policy statement. Further to the work and mission of the Church of Scotland and the terms of the Bribery Act 200

More information

nib holdings limited ABN and all related entities within the nib Group ( nib Group ) or ( nib ) Dated 13 February 2017

nib holdings limited ABN and all related entities within the nib Group ( nib Group ) or ( nib ) Dated 13 February 2017 nib holdings limited ABN 51 125 633 856 and all related entities within the nib Group ( nib Group ) or ( nib ) Dated 1 Purpose 2 1.1 Scope of this document 2 1.2 Who does the anti-bribery policy apply

More information

Anti-Bribery and Corruption Policy JUNE 2017

Anti-Bribery and Corruption Policy JUNE 2017 Anti-Bribery and Corruption Policy JUNE 2017 Introduction Resolute Mining Limited and each subsidiary and related companies (Resolute) is committed to being a responsible corporate citizen. Resolute interprets

More information

Anti-Fraud, Corruption and Bribery Policy

Anti-Fraud, Corruption and Bribery Policy Anti-Fraud, Corruption and Bribery Policy Policy Reviewed and Adopted by Board of Trustees: Version Date of Next Review: Responsible Officer: 1 Purpose The purpose of this policy is to confirm Prince Regent

More information

THE BRIBERY ACT 2010 POLICY STATEMENT AND PROCEDURES

THE BRIBERY ACT 2010 POLICY STATEMENT AND PROCEDURES THE BRIBERY ACT 2010 POLICY STATEMENT AND PROCEDURES DECEMBER 2011 CONTENTS Page 1. Introduction 2 2. Objective of This Policy 3 3. The Joint Committee s Commitment to Action 3 4. Policy Statement Anti-Bribery

More information

Anti-Corruption and Bribery Policy

Anti-Corruption and Bribery Policy 1. Introduction Anti-Corruption and Bribery Policy 1.1 It is the School's policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption

More information

ANTI-BRIBERY & CORRUPTION POLICY

ANTI-BRIBERY & CORRUPTION POLICY ANTI-BRIBERY & CORRUPTION POLICY 0 Anti-Bribery and Corruption Policy 1 Anti-Bribery and Corruption Policy Introduction This policy applies to Portmeirion Group PLC and its subsidiaries, (including Wax

More information

Warrego Energy Limited Level 6, 10 Bridge Street, Sydney NSW 2000 T: E: warregoenergy.com ABN

Warrego Energy Limited Level 6, 10 Bridge Street, Sydney NSW 2000 T: E: warregoenergy.com ABN Warrego Energy Limited ACN 125 394 667 WARREGO ENERGY LIMITED ANTI-CORRUPTION & BRIBERY POLICY Contents SECTION 1. Warrego s commitment to ethical performance 1 2. Who is covered by the policy? 2 3. What

More information

Wilmington Anti-Bribery and Corruption Policy Standard. Effective Date : June 2012

Wilmington Anti-Bribery and Corruption Policy Standard. Effective Date : June 2012 Wilmington Anti-Bribery and Corruption Policy Standard Effective Date : June 2012 Table of Contents 1. Executive Summary 1 2. Who this Policy Applies to 1 3. Who is Responsible for this Policy 2 4. Key

More information

Anti-Bribery and Corruption Policy

Anti-Bribery and Corruption Policy Anti-Bribery and Corruption Policy In this policy, the references for Company, we, our, us, refer to the Lubbers Transport Group and its subsidiary companies. Compliance Manager means Stuart Ferguson,

More information

COUNTER FRAUD, BRIBERY AND CORRUPTION POLICY AND RESPONSE PLAN

COUNTER FRAUD, BRIBERY AND CORRUPTION POLICY AND RESPONSE PLAN SCHEDULE 10 COUNTER FRAUD, BRIBERY AND CORRUPTION POLICY AND RESPONSE PLAN ABERTAWE BRO MORGANNWG UNIVERSITY LHB The policy has been screened for relevance to equality. No potential negative impact has

More information

WHISTLE BLOWING POLICY

WHISTLE BLOWING POLICY 1 WHISTLE BLOWING POLICY 1 1. What is Whistle Blowing? Whistle blowing inside the work place is the term used to describe reporting by employees or exemployees, of wrongdoing on the part of management,

More information

Anti-Bribery Policy. Anti-Bribery. Policy. Working Together. January Borders College 15/2/ Working Together.

Anti-Bribery Policy. Anti-Bribery. Policy. Working Together. January Borders College 15/2/ Working Together. Anti-Bribery Working Together Policy January 2016 Borders College 15/2/2016 1 Working Together History of Changes Version Description of Change Authored by Date 1.1 New Policy approved at Audit Committee

More information

I. STATEMENT OF COMMITMENT AGAINST CORRUPTION, BRIBERY & EXTORTION

I. STATEMENT OF COMMITMENT AGAINST CORRUPTION, BRIBERY & EXTORTION CITY DEVELOPMENTS LIMITED ANTI-CORRUPTION POLICY & GUIDELINES* (*All employees of CDL are required to read the full version of the CDL Anti-Corruption Policy & Guidelines, which is available on CDL s intranet,

More information

Telephone No:

Telephone No: Church Hill School Burlington Rise East Barnet Herts EN4 8NN Telephone No: 020 8368 3431 Fax: 020 8368 1602 e-mail: office@churchhill.barnetmail.net Name of policy: Whistleblowing Policy REVISION HISTORY

More information

Anti-Fraud, Bribery & Corruption Policy. Version 3.0

Anti-Fraud, Bribery & Corruption Policy. Version 3.0 Anti-Fraud, Bribery & Corruption Policy Version 3.0 Standard Operating Procedure St Helens CCG Anti-Fraud, Bribery & Corruption Policy Version 3.0 Implementation June 2013 Date Review Date March 2021 Approved

More information

CHURCH OF SCOTLAND CONGREGATION SC[INSERT CHARITY NUMBER]

CHURCH OF SCOTLAND CONGREGATION SC[INSERT CHARITY NUMBER] BRIBERY AND PROCUREMENT POLICY OF [INSERT NAME] CHURCH OF SCOTLAND CONGREGATION SC[INSERT CHARITY NUMBER] (N.B. WHEN COMPLETING THE POLICY, WHERE THE ALTERNATIVES [KIRK SESSION/CONGREGATIONAL BOARD] ARE

More information

This guidance applies to all members of the University including all employees and independent members of Council and its Committees.

This guidance applies to all members of the University including all employees and independent members of Council and its Committees. UNIVERSITY OF ULSTER ANTI- BRIBERY GUIDANCE 1. Introduction This guidance applies to all members of the University including all employees and independent members of Council and its Committees. 2. Position

More information

UACN WHISTLEBLOWING POLICY

UACN WHISTLEBLOWING POLICY UACN WHISTLEBLOWING POLICY JULY 2015 VERSION 2.0 Document approval This document was approved by the Board of UAC of Nigeria PLC on 29 th July 2015 2 Table of Contents 1. Policy Statement..... 4 2. Application.....

More information

CORPORATE GOVERNANCE & PUBLIC INTEREST DISCLOSURE

CORPORATE GOVERNANCE & PUBLIC INTEREST DISCLOSURE SECTION 15 CORPORATE GOVERNANCE & PUBLIC INTEREST DISCLOSURE CONTENTS CORPORATE GOVERNANCE GENERAL BACKGROUND 3 THE COUNCIL - BACKGROUND 3 ACCOUNTABLE OFFICER 4 GOVERNING BODY: THE COUNCIL 5 SCHEME OF

More information