1. Introduction and Scope 

The University is committed to the highest standards of integrity, probity and ethics in all its dealings - wherever they may take place and in whatever context.

Bribery is both illegal and unethical, and brings with it the potential for criminal liability and severe penalties - at both University and individual level. The legislation is extensive and, crucially, the University’s anti-bribery responsibilities do not end at the office door or campus gate. Those responsibilities potentially extend to any associated person, representative, agent, subsidiary, partnership or body engaged on University business, including those within and outside of the UK. University of Derby Approach The University has a zero tolerance approach to bribery and serious action will be taken against anyone found to be involved in bribery, up to and including dismissal under the University’s disciplinary processes.

For associated persons, breach of this policy may result in contractual, legal and/or other sanction(s).


This policy applies to all University staff and students. It also applies to agency and self- employed workers working for the University, and all other persons associated with and acting for the University, whether directly or indirectly.

This definition includes external members of University Committees, representatives, agents, subsidiaries, individuals appointed as directors of any company, consultants, contractors and partners.

To the fullest extent permissible by law, this policy shall apply in all jurisdictions in which the University operates. Bribery risks It should be stressed that, in common with other Higher Education Institutions (HEIs), the University faces a range of bribery risks throughout its activities, operations and geographies. These risks include, but are not limited to, bribery in relation to admissions, examinations, awards, procurement, construction and field trips. 

2. The Bribery Act 2010

The Act came into force in July 2011. It is a cleverly worded and comprehensive piece of legislation which has extensive scope and geographic reach. What is a bribe? Bribes can take many forms but typically they involve corrupt intent. A bribe could be

According to the Act, bribery is where someone requires, gives or promises financial (or other) advantage with the intention of inducing or rewarding improper performance. Improper performance is a key concept and generally means where an individual does not act in good faith, impartially and/or properly. The test of what is proper is based upon what a person in the UK would reasonably expect.

A typical example of improper performance could involve work being continually directed to a particular construction contractor at the expense of other qualified contractors as a result of bribery - work that has (invariably) been overpriced to allow for the bribery payments required. Under the Act, there are general forms of bribery where individuals are personally criminally liable:

The University does not offer or make, and shall not demand or accept, facilitation payments of any kind. Advice should be sought if required in order to distinguish between properly payable fees and disguised requests for facilitation payments. Overseas reach The Bribery Act has extensive global reach and holds UK organisations liable for failing to implement adequate procedures sufficient to prevent such acts by those working for the University or on its behalf, no matter where in the world the act takes place. In addition, current US legislation (Foreign Corrupt Practices Act or FCPA) offers similar prohibitions and potential penalties, and is enforced robustly by the US authorities, supported by extensive inter-agency co-operation on an international basis.

3. University of Derby Policy

The University values its reputation for ethical behaviour and recognises that any involvement in bribery is illegal and will reflect adversely on its hard-earned image and reputation.

The University prohibits the offering, giving, soliciting or the acceptance of any bribe in whatever form to, or from, any person or company (public or private) by anyone associated with the University. The University expects any person or company (public or private) associated with the University to act with integrity and without any actions that may be considered an offence within the meaning of the Bribery Act 2010.

The University requires any potential breaches of this policy and bribery offers to be reported under the University’s reporting processes (see below). The prevention, detection and reporting of bribery is the responsibility of everyone associated with the University.

4. Prevention of Bribery and Corruption

The University takes the following steps to assist in the prevention of Bribery and Corruption Senior Management Commitment The Governing Council and Vice-Chancellor’s Executive are committed to carry out all academic and business functions fairly honestly and openly. They will ensure processes and practices are followed in a robust manner to ensure bribery and corruption are dealt with in line with the Bribery Act 2010.

Risk Management

Effective risk management is both central to this policy and an essential part of the University’s overall governance process. It facilitates identification of the specific risk areas where the University could face bribery and corruption risks and allows mitigating plans and actions and protections to be put in place. 

Risk Assessment

The University Senior Managers carry responsibility for risk assessment alongside appointed Risk Managers in Colleges and Departments who will carry out risk assessment in each area of activity, considering its activities, both internal and external, the countries where it does business, the sector in which it operates, the types of transactions it undertakes, the business partners it chooses.

Bribery risk assessment should be considered as part of overall risk assessment, with a higher profile in areas of high expenditures and contract letting. Areas of High Risk University high risk areas will change over time: continuing enhanced diligence areas include:

Due Diligence

The University will conduct pre contract due diligence on all third parties who provide services on its behalf. This will particularly apply to Procurement and Financial processes with regard to selecting suppliers. Contract conditions will be updated to reflect Bribery Act considerations for suppliers who will be asked to declare support for our Anti-Bribery Policy.

Communication and Training

The policy will be published on the University website. All employees connected with buying or contracting will receive direction and training both from Procurement on their specific high value transactions and also from Finance generally: managers will be trained to assess and identify areas and employees at higher risk.

Monitor and Review

The University will review it policies and practices on a continuing basis to ensure risk assessment is perpetual with each transaction type considered separately. The University will be particularly diligent around new activity.  Formal declarations by the members of the Extended Vice-Chancellor’s Executive will be requested annually

5. Gifts and Hospitality

Gifts and Hospitality (and Entertainment) include the receipt or offer of gifts, meals, tokens of appreciation, invitations and tickets to events and functions in matters connected with our business. These are acceptable provided that they fall within reasonable bounds of value and occurrence, subject to the further provisos listed and described below

Gifts and Hospitality

Employees need to consider when offered a Gift or a Hospitality:

Clearly, gifts and hospitality can amount to real or perceived bribery and caution should always be exercised. It is down to the employee to make this judgement but if there is any doubt about the propriety of hospitality, it should not be accepted or offered.

Acceptance of Gifts and Hospitality:

Employees accepting G&H should declare the receipt to the Procurement Department who will review (with payroll) for any taxable ‘benefit in kind’. Staff can find a copy of the Gifts and Hospitality Notification Form on the Procurement pages of the Intranet.

Staff must also notify their line manager.

The Clerk to the Governing Council holds the register for the (Extended) Executive and the Governing Council.

6. If you see Bribery and Corruption in the Workplace

All employees of the university have a responsibility to help detect, prevent and report instances of bribery and suspected bribery, this extends to all suspicious activity or wrongdoing. The University is committed to a safe, reliable and confidential way of reporting suspicious activity. If you are concerned, know or suspect that bribery is taking place, see your line manager in the first instance, or if this is not possible or advisable, contact the Financial Controller or Procurement.

7. Anti-Bribery Whistleblowing Policy

The Whistleblowing Policy is designed to allow staff, student and all members of the University to raise at high level concerns which they believe in good faith provides evidence of malpractice or impropriety. Individuals discovering or suspecting malpractice, impropriety or wrongdoing are able to disclose the information without fear of reprisal. A disclosure in good faith which is subsequently not confirmed, will not lead to action against the person making the disclosure.



Appendix 1

Examples of Risk Areas for the University of Derby

The following are examples of a range of UK and overseas activities which, depending on the circumstances, could lead to breaches of the Act by the employees or the University.

Where risk regarding a third-party arrangement has been identified, employees must:


Appendix 2

The basic Dos and Don’ts that all University employees must adhere to.





If you have any queries about this policy, please email 



Last reviewed: 30/10/2020

Policy Owner: Finance - Procurement