The Bribery Act 2010 was introduced some time ago now, so Universities would be well-advised to review their anti-bribery policies, and consider whether their adequate procedures are still fit for purpose and are actually being followed.  For example, relevant staff training should have been rolled out back in 2011 when the Act came into force, but have there been refreshers?  Have new starters been trained?  Are hospitality and gift registers actually being maintained? Remember to keep an eye on relationships in high risk jurisdictions and check the latest Corruption Perceptions Index, particularly where public officials may be involved.  Has the University signed off on a renewed institutional agreement but not renewed the due diligence?  Has it appointed recruitment agents in new jurisdictions?  Whether an institution is deemed to have adequate procedures will depend on its context and particular risks, so it is worth looking at whether those have changed since policies were first drafted.


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