Anti-Bribery Arrangements
Anti-Bribery
The Bribery Act 2010 took effect from 1 July 2011. The Act contains two general offences covering the offering, promising or giving of a bribe (active bribery) and the requesting, agreeing to receive or accepting of a bribe (passive bribery).
It also sets out two further offences which specifically address commercial bribery. The first relates to bribery of a foreign public official in order to obtain or retain business. Very importantly, the second one creates a new form of corporate liability for failing to prevent bribery on behalf of a commercial organisation. This now places a duty on all commercial organisations (which includes the University in its scope) to put procedures in place to prevent bribery by persons associated with them.
LJMU has prepared an Anti-Bribery Policy which includes a statement by the Chairman of the Board of Governors. This was agreed by the Board at its meeting on 28 March 2011.
A Working Group has developed supporting materials and guidance for all staff and for where there are areas of business with higher risks. It has prepared a draft letter for use with those with and through whom the University undertakes business, e.g. contractors, partners and agents, together with a Bribery Risk Assessment Form.
A reference to the Anti-Bribery Policy is now included in the Code of Conduct for Staff document as well as in other HR documents. The Gifts and Hospitality Policy provides information to be read in conjunction with the Anti-Bribery policy.
There is a presentation to brief staff on anti-bribery and some Frequently Asked Questions.
Further information about the Act and the procedures to be put in place to prevent bribery can be found in the Ministry of Justice Guidance on the Act http://www.justice.gov.uk/guidance/docs/bribery-act-2010-guidance.pdf
