Anti-Bribery and Anti-Corruption Policy

Watney College adopts a zero-tolerance approach to bribery and corruption in all forms. This policy sets out our legal obligations, prohibited conduct, reporting mechanisms and governance arrangements.

Commitment, scope and definitions

Watney College is committed to conducting all academic, financial and commercial activities with integrity, transparency and accountability. Failure to prevent bribery is a criminal offence under UK law.

This policy applies to:

Board members and committee members
All employees and consultants
Agents and recruitment partners
Suppliers and contractors
Students acting in an official or representative capacity

Legal framework

Bribery Act 2010 · Public Interest Disclosure Act 1998 · Employment Rights Act 1996 · Data Protection Act 2018

What counts as an improper advantage

Cash payments · Gifts · Hospitality beyond reasonable proportion · Commission payments · Facilitation payments · Undisclosed referral incentives

Prohibited conduct

It is strictly prohibited to offer or accept any bribe, make facilitation payments, or provide inducements to awarding body representatives, students, agents or regulators.

No employee or representative may authorise any payment or benefit intended to improperly influence:

Admissions decisions
Assessment outcomes
Validation or accreditation processes
Regulatory inspections
Procurement decisions

Gifts and hospitality

Proportionate hospitality may be permitted only where it is reasonable and modest, properly recorded, and not linked to decision-making. All gifts and hospitality require prior written approval from the Principal. A central register is maintained by the Finance Office and reviewed by the Audit, Remuneration & Risk Committee.

Due diligence

Proportionate due diligence is conducted on agents, overseas recruitment partners, suppliers and contractors. All contracts include anti-bribery clauses.

Governance, reporting and investigation

Governance accountability:

Board of Directors — ultimate accountability for adequate procedures
Audit, Remuneration & Risk Committee — monitors controls, reviews whistleblowing reports, oversees investigations
Academic Board — protects academic integrity from corrupt influence
Principal — operational implementation and prompt investigation

Raising a concern

Concerns may be raised via line manager, Principal, Chair of ARRC, or Chair of the Board. This policy operates alongside the Whistleblowing (Protected Disclosure) Policy. Individuals raising concerns in good faith are protected from detriment.

Consequences of breach

Confirmed breaches may result in disciplinary proceedings, termination of employment or contract, referral to law enforcement, and revocation of academic awards where applicable.

Risk escalation framework

Risk level	Responsible body
Programme-level concerns	Quality Assurance Committee
Institutional academic integrity risk	Academic Board
Material regulatory or reputational risk	College Oversight Board
Financial / compliance risk	Audit, Remuneration & Risk Committee
Ultimate accountability	Board of Directors

Last reviewed: 5 November 2025 · Version: 1.0 · Next review: November 2026

Download the full Anti-Bribery and Anti-Corruption Policy (PDF)