Policy 8.15 Anti-bribery Policy

8.15 Anti-bribery Policy

Leeds University Union is committed to the highest standards of ethical conduct and integrity in our activities. This policy outlines our position on preventing bribery. LUU will not tolerate any form of bribery by, or of, its employees, trustees, or any person or body acting on LUU‟s behalf. The Senior Leadership Team is committed to putting effective measures in place to prevent, monitor and eliminate bribery.

This policy applies to all LUU employees and officers and to temporary workers, consultants, contractors, agents and subsidiaries acting for or on behalf of LUU. Any breach of this policy is likely to result disciplinary action and is potentially a criminal matter for the individual involved.

The Bribery Act 2010

LUU prohibits employees or associated persons from offering, promising, giving, soliciting or accepting a bribe. The bribe might be cash, a gift or other promise to, or from a person or organisation. For example, a bribe might made to convince an employee to act unfairly when deciding whether to maintain a business relationship with another organisation in order to gain a personal advantage for themselves or anyone connected with them. Under the Act LUU may face criminal liability for unlawful actions taken by its employees or associated persons.

LUU’s Financial Procedures

To guard against potential bribery risks, all employees must take particular care to ensure that all LUU records are accurately maintained when dealing with any contracts or business activities in line with LUU’s Financial Procedures. This includes all financial invoices and payment transactions with clients, suppliers and public officials.

Due diligence should be taken by everyone before entering into a contract arrangement or relationship with any potential supplier (including agents and consultants). You are also required to keep accurate and up-to-date records of all hospitality and entertainment. Further details of how records of such transactions should be recorded can be found in LUU‟s financial procedures.

Staff members need to ensure they adhere to LUU’s full Financial Procedures document. This document will be made available to you during your induction period. It can also be accessed at any point for reference on the Google Link here:

https://drive.google.com/drive/folders/0BxTwGkhs7VORZW5tQVdDazl3NVE

If you have any difficulty accessing this, please speak to your line manager.

Entertainment, gifts and hospitality

LUU allows employees to accept some entertainment, gifts and hospitality provided that it is in moderation and for the purpose of maintaining good business relationships. This is provided that it is in good faith and not offered, promised or accepted to secure an advantage for LUU or to influence the employee receiving the gift.

Any gifts, rewards or entertainment received or offered from clients, suppliers or other business contacts should be reported immediately to your line manager. In certain circumstances, it may not be appropriate to keep such gifts or be provided with the entertainment and employees may be asked to return the gifts or refuse the entertainment. As a general rule, small tokens of appreciation, such as flowers or a bottle of wine, may be accepted and handed in to the People Team which will be used for staff prizes, raffles etc.

If an employee or associated person wishes to provide gifts to someone outside LUU, approval from the individual’s line manager is required, together with details of the recipients and reasons for the gift. These will be authorised only in special circumstances and will be subject to a cap of £20 per recipient. You must always supply records and receipts in accordance with LUU‟s expenses policy.

Charitable donations

LUU considers that charitable giving forms part of its wider commitment to the community and directs all fundraising activities through our Raise and Give (RAG) Society. LUU also supports our employees involved in fundraising events.

Risk management

Bribery is identified as a risk within LUU‟s established risk management procedures. LUU‟s Risk Register helps to detect and prevent bribery through conducting risk assessments to identify high-risk areas of activity on a regular basis.

Reporting suspected bribery

LUU depends on its employees to ensure that the highest standards of ethical conduct are maintained in all its activities. If you suspect or discover something of this nature, you are encouraged to report it immediately. Further details of how to do this and your rights to full protection can be found under LUU‟s Whistleblowing policy. LUU will fully investigate any instances of alleged or suspected bribery in line with the Disciplinary Procedure. If the allegations are proven they may result in a finding of gross misconduct and immediate dismissal. Depending on the circumstances, the matter may also be reported to the relevant authorities.