Anti-Bribery and Corruption Policy

Introduction

The Oxford College of Business and Management (https://www.ocbm.uk/) (“OCBM”, “we”, “us”, or “our”), including our sub-brands eConsultancy OCBM (https://econsultancy.ocbm.uk/) and eLearning OCBM (https://elearning.ocbm.uk/), collectively referred to as the “Websites”.

 

1. Purpose

Anti-bribery and corruption policy is established to ensure that Oxford College of Business and Management conduct all business activities in full compliance with the UK Bribery Act 2010 (“the Act”) and other relevant legislation. The policy is designed to protect OCBM from the legal and reputational risks associated with bribery and corruption and to foster a culture of integrity and transparency.

 

2. Scope

This policy applies to all employees, officers, directors, contractors, educators, consultants, and any other persons associated with OCBM, irrespective of their location. It extends to all business dealings and transactions in all jurisdictions in which we operate.

 

3. Legal Framework

The UK Bribery Act 2010 is one of the strictest anti-corruption laws globally and applies to OCBM and its sub-brands eConsultancy and eLearning, regardless of where bribery and corruption occur. The Act criminalizes:

3.1.    Active Bribery: Offering, promising, or giving a bribe.

3.2.   Passive Bribery: Requesting, agreeing to receive, or accepting a bribe.

3.3.   Bribery of Foreign Public Officials: To obtain or retain business or an advantage in the conduct of business.

3.4.   Failure of Commercial Organizations to Prevent Bribery: The organization may be held liable if it fails to prevent persons associated with it from engaging in bribery.

 

4. Policy Statement

OCBM adopt a zero-tolerance approach to bribery and corruption. This policy prohibits:

4.1.    Offering, promising, or giving any financial or other advantage to another person with the intent to induce them to perform improperly a relevant function or activity.

4.2.   Requesting, agreeing to receive, or accepting any financial or other advantage for performing a relevant function or activity improperly.

4.3.   Engaging in any act that could be considered as bribery under the UK Bribery Act 2010.

4.4.   Making facilitation payments (small unofficial payments made to expedite routine actions).

4.5.   Using third parties to commit bribery on behalf of OCBM.

 

5. Gifts, Hospitality, and Charitable Donations

5.1.    Gifts and Hospitality: All gifts and hospitality offered or received must be proportionate, reasonable, and approved in advance by management. These must never influence business decisions or appear to be intended to do so.

5.2.   Charitable Donations: Donations to charities must be transparent, approved by senior management, and not made to gain any improper advantage.

 

6. Third-Party Relationships

OCBM will conduct appropriate due diligence on all third parties, including agents, contractors, and partners, to ensure they are reputable and have no history of bribery or corruption. Contracts with third parties must include clauses that require compliance with the UK Bribery Act 2010 and allow for termination in case of any breach.

 

7. Facilitation Payments

Facilitation payments are illegal under the UK Bribery Act and are strictly prohibited by OCBM. All employees and associated persons must reject any request for such payments and report them to the Compliance Officer immediately.

 

8. Political Contributions

OCBM do not make contributions to political parties or candidates. Any political donations or sponsorships are strictly forbidden, as they can be construed as attempts to influence government action.

 

9. Responsibilities

9.1.    Employees and Associated Persons: Must familiarize themselves with this policy, comply with its terms, and attend any required training sessions. They must also report any suspected breaches.

9.2.   Senior Management: Must ensure that this policy is effectively implemented within their areas of responsibility. Senior management is also responsible for fostering a culture of compliance and ethical behaviour.

9.3.   Compliance Officer: Responsible for overseeing the implementation of this policy, providing guidance, and ensuring that the company’s procedures are aligned with legal requirements.

 

10. Reporting Violations

Employees, contractors, and third parties are encouraged to report any suspicious activities or concerns related to bribery or corruption to the Compliance Officer. Reports can be made anonymously and will be treated confidentially. Retaliation against anyone who reports a concern in good faith is strictly prohibited.

 

11. Penalties for Non-Compliance

Non-compliance with this policy could result in disciplinary action, including termination of employment or contractual agreements. Legal action may also be taken against individuals or entities involved in bribery or corruption, which could result in criminal prosecution, fines, and imprisonment under the UK Bribery Act.

 

12. Training and Communication

OCBM will provide regular training to all employees and associated persons to ensure they understand their obligations under the UK Bribery Act 2010 and this policy. The policy will be communicated to all employees, partners, and contractors, and will be readily accessible on our internal and external platforms.

 

13. Monitoring and Review

This policy will be reviewed annually by the Compliance Officer to ensure its continued relevance and effectiveness. The review will consider any changes in legislation, organizational structure, or other relevant factors. Any necessary updates will be made, and all employees will be informed accordingly.

14. Approval and Ownership

This policy is approved by the Board of Directors of OCBM. The Compliance Officer is responsible for maintaining, updating, and ensuring adherence to this policy.

 

Contact Information

For any inquiries or feedback, please contact us at:

Oxford College of Business and Management
Address: [MC 101, 3 HQ, The Quadrant, Warwick Road Coventry UK, Postcode: CV1 2DY]
Email: [info@ocbm.uk]

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This “Anti-bribery and corruption policy” is effective as of 1st August 2024.

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Thank you for your trust in Oxford College of Business and Management. We are committed to providing the best education and consultancy services.