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The Vice-Chancellor’s Group requires all staff who are responsible for specifying, managing or influencing the procurement of goods or services to take particular care to ensure that there can be no criticism that unequal treatment has been given to any supplier through the acceptance of gifts and/or other benefits, such as hospitality. It is the responsibility of the member of staff in receipt of or providing a gift or hospitality to record this in a timely manner on the register in accordance with this policy. Please also see the Conflict of interest policy, Bribery Act 2010 and Code of conduct for staff and section 5.2 of the Procurement Policy.
The provisions of the Bribery Act 2010 have increased the need for vigilance in this area, as the University and/or its staff may be rendered liable for prosecution if evidence of receiving or offering bribes or inducements can be demonstrated. This extends to those over whom the University is deemed to have control, such as overseas agents. Further information on the Bribery Act can be found at the link above. In order to protect staff and the reputation of the University from accusations of bribery or corruption staff are not permitted, directly or indirectly, to accept any gift, hospitality, reward or other benefit from any source (including organisations, students, other employees and members of the public) with whom s/he has been brought into contact or maintains contact only by reason of the duties for which they are employed by the University except in the following circumstances:
Staff responsible for the purchase of supplies, equipment or services must take particular care to ensure that there can be no criticism that unequal treatment has been given to suppliers involved in tendering processes through the acceptance of gifts or other benefits. Staff should always bear in mind the need not to behave so that the impression might be given or interpreted by any member of the public, student or organisation with whom they deal that they may be influenced by any gift, benefit or behaviour to show favour or disfavour to any person or organisation in respect of the work for which they are employed.
If a member of staff is in any doubt as to the propriety of receiving any gift or hospitality then the employee must consult their PVC Dean or Director. Subject to the exceptions noted in 1 - 3 above, all gifts, hospitality and benefits whether provisional, given, received or declined should be recorded on the current Gifts and Hospitality Register. It is the responsibility of the member of staff in receipt of or providing a gift or hospitality to record this on the register in a timely manner. Employees who are found not to have acted in accordance with this policy may be disciplined and in serious cases may be dismissed on the grounds of gross misconduct.
Reviewed February 2018