Anti-Bribery and Corruption Policy

Cenit College aims to conduct its business in accordance with legislation and in a proper and professional manner. Cenit College is committed to applying the highest standards of conduct and integrity in its business activities in the UK and overseas and as such does not tolerate bribery or corruption.

Bribery and corruption should be avoided at all times, in our dealings in and with all business in all countries. This policy sets out a single standard that all employees must comply with, regardless of whether local law or practices might permit something to the contrary. Failure to comply with this policy, whether or not this is intentional, may lead to disciplinary action (up to and including dismissal), and criminal liability for the individual involved (up to and including imprisonment).

This policy will be owned by the Board of Directors.

This policy is designed to help employees identify when something is prohibited so that bribery and corruption is avoided and provides help and guidance if there is any doubt about whether there is a problem, and further advice is required. The Anti Bribery Policy extends to all of Cenit College’s business dealings and transactions; in all countries in which it or its subsidiaries and associates operate. A business associate includes employees including retained consultants and agency staff, subcontractors and suppliers, joint venture partners, agents.

Cenit College is committed to full compliance with all relevant anti-bribery and corruption laws and regulations, including the Bribery Act 2020. There are four key offenses under the Act:

• Bribery of another person
• Accepting a bribe
• Bribing a foreign official
• Failing to prevent bribery.

This policy applies to all employers and associated persons in Cenit College. They are required to comply with this policy, in accordance with the Bribery Act 2010.

The Board of Directors has overall responsibility for this policy and monitoring the effectiveness of the actions taken under this policy and any subsequent review required.

The senior managers have a responsibility for implementing this policy in the area that they manager. Should training be required the senior managers are responsible for ensuring that their staff receive the appropriate training.

Employees and associates have a responsibility to adhere to this policy and seek guidance from their managers or the Managing Director where appropriate.

Bribery: The UK guidelines for the 2010 Anti-bribery Act define bribery as “giving someone a financial or other advantage to encourage that person to perform their functions or activities improperly or to reward that person for having already done so”. This includes.

• Bribery of another person
• Accepting a bribe
• Bribing a foreign official
• Failing to prevent bribery.

“A bribe does not need to be a monetary sum. A bribe can be any type of gift, consideration or advantage offered or requested, for example, an award of a contract, a discount in a commercial transaction or an offer of employment.

The Anti-bribery Act is not concerned with fraud, theft, books and record offences, Companies Act offences, money laundering offences or competition law. Further detail about what is covered by the Act can be found in ‘The Bribery Act 2010 – Guidance about procedures which relevant commercial organisations can put into place to prevent persons associated with them from bribing (section 9 of the Bribery Act 2010)’ – www.justice.gov.uk/ guidance/bribery.htm

Corruption is any abuse of a position of trust in order to gain an undue advantage. Bribery is a means of causing corruption.

A political contribution is any donation or other form of support provided to a political party or a person who is standing for public office.

Facilitation payments are small payments made to speed up an administrative process or secure a routine government action by an official. They are most frequently encountered in high-risk countries. Facilitation payments should be contrasted with official, lawful payments (which will be made to an organisation rather than an individual official) to expedite certain functions (e.g., where there is a fast-track service to get a passport).

High-risk countries are countries where bribery and corruption are reasonably common. The Corruption Perceptions Index published by Transparency International www.transparency.org is a good indicator of the risk of bribery and corruption in individual countries. A country with a score of 50 or below should usually be considered a high-risk country for the purposes of this Policy.

Employees of Cenit College must never:

• Offer, give or accept a bribe.
• Make a payment or offer a personal advantage to someone if you know or believe that this will involve that person or any other person misusing their position or performing their functions improperly.
• Misuse your position or perform your functions improperly in connection with any payments or other personal advantage offered or provided to you or any other person.

In an effort to prevent bribery, and guided by the Anti-Bribery Act 2010, Cenit College will be guided by the following principles: Cenit College will.

• Provide a clear definition of what is anti-bribery.
• Ensure that the actions Cenit College takes to prevent bribery will be proportionate to the risks we face and the size of our business.
• Ensure the Board of Directors instil an anti-bribery culture within their organisations and demonstrate a commitment to prevent bribery.
• Prepare a risk assessment on its exposure to bribery and solutions on how to deal with those risk.
• Perform due diligence on those we employ and those we conduct our business with.
• Communicate the organisations policies and procedures to employees and to others who will perform services for the organisations, in order to enhance awareness and help to deter bribery by making clear the basis on which Cenit College does business. Training to increase awareness will be provided to all employees.
• Encouraging its employees to be vigilant and to report any suspicions of bribery and to provide them with suitable channels of communication and to ensure sensitive information is treated appropriate in a confidential manner to a designated senior manager.
• Review and monitor its anti-bribery steps on an annual or more frequent basis as relevant.
• Include clauses in contracts to prevent bribery.
• Taking firm and vigorous action against any individual(s) involved in bribery.

The following sections describe the procedure for raising a concern, and investigation of bribery and corruption.

1.8.1 Procedure for an employee raising a concern.

If an employee is concerned that a corrupt act is being considered or carried out, they should report the matter to their line manager in the first instance. If it is not possible to speak to the line manager for some reason, then the Director of Human Resources, Organisation and Strategy should be contacted. More details of how to go about reporting your concerns can be found in the Whistleblowing Policy.

The policy is designed to allow employees, students and all members of Cenit College to raise, at high level, concerns or information which they believe in good faith provides evidence of malpractice or impropriety. Individuals discovering apparent evidence of malpractice, impropriety or wrongdoing within the organisation should feel able to disclose the information appropriately without fear of reprisal. A disclosure made in good faith which is not confirmed by subsequent investigation will not lead to any action against the person making the disclosure. Individuals making disclosures which are found by subsequent investigation to be malicious and/or vexatious may be subject to disciplinary or other appropriate action.

1.8.2 Procedure for investigating a concern.

The procedure for investigating a concern for corruption or bribery will follow the same process as that outlined in the whistleblowing policy.

1.8.3 Facilitation Payments

Facilitation payments are considered bribes and are not allowed. If you are asked for a payment and are concerned that it is a facilitation payment, you should:

• Ask for a receipt for the payment.
• If no receipt will be provided, politely decline to make the payment and explain that it is not allowed under your company’s internal policies.
• If possible, speak to the official’s supervisor, so you can explain your position.
• Keep a note of the request and other circumstances and report them as soon as possible to your line manager or the Managing Director.

1.8.4 Gifts and Hospitality

Gifts and hospitality must only be offered or accepted where they are infrequent, reasonable and not excessive and where there is no risk that they will improperly influence or be seen to improperly influence a decision. In particular, there must be no express or implied link between any gift or hospitality and the terms on which the business operations Cenit College perform.

Guidelines for accepting gifts and hospitality.

• Providing or accepting hospitality is only allowed where its purpose is to develop legitimate business relationships.
• It must be proportionate having regard to the recipient and the organisation concerned.
• Gifts must be modest in value, such as a token of appreciation to mark a national holiday or at another special time such as the completion of a project with a customer or supplier.
• No gift should be given if it could be misconstrued as a reward, an inducement or other corrupt act.
• Cash or cash equivalents must never be given or accepted.
• You must not offer or give a gift or hospitality if you are aware or should be aware that it is in breach of the rules of the organisation where the recipient works or applicable laws on what they can accept.
• Cenit College directors must ensure that all spending on gifts and hospitality is recorded in detail and accounted for appropriately. Each employee must comply with those policies and procedures, in addition to this Policy.

1.8.5 Sponsorship, Charitable and Political Contributions

Sponsorship and charitable donations or Political Contributions by Cenit College must be approved in writing in advance by the Managing Director. Detailed records must be kept of any sponsorship or charitable donations made. Requests for sponsorship made by Cenit College employees, to customers, suppliers or other third parties should only be made with the prior approval of the Managing Director.

Cenit College Representatives

If any organisation or individual is engaged to represent Cenit College (i.e., sales agent etc). Cenit College  will.

• Carry out suitable checks to ensure these representatives that we want to use, have not previously had any history of involvement in bribery, corruption or other illegal or improper practices.
• Ensure that we communicate to the representative is completely clear that they must not get involved in bribery or corruption in connection with the work they do for us. This will be communicated as a clause in our contracts with them.
• Risks need to be included in our Risk Register with the appropriate resolutions.
• Currently we do not do business in high-risk countries. Should that position change, the organisation will need to put effective controls in place.

This policy will be reviewed annually by the board of directors.

The monitoring instruments are as follows.

• Clauses denouncing bribery and corruption are included in contracts.
• All gifts and hospitality are recorded in our books and accounted for.
• Confirm that where a concern has been raised that the documentation is held in a secure location that is password protected.