Stonebridge University is committed to conducting all of its activities with integrity, transparency, and accountability. This policy sets out our zero-tolerance stance on bribery and corruption and ensures compliance with:

• The UK Bribery Act 2010,
• The U.S. Foreign Corrupt Practices Act (FCPA) (where applicable), and
• Other international anti-corruption laws.

The purpose of this policy is to:

• Promote honesty and ethical behaviour in all university dealings.
• Protect the reputation and values of Stonebridge University.
• Ensure that all staff, contractors, and representatives act lawfully and responsibly.

This policy applies to:

• All employees of Stonebridge University (academic, administrative, and support).
• Contractors, consultants, partners, and service providers.
• Students, alumni, and other representatives acting on behalf of the University.

It applies to all interactions with:

• Other universities, institutions, and partners.
• Students and their families.
• Third-party service providers and agents.
• Government officials and regulators.

The University Compliance Committee, under the authority of the Board of Directors, holds final responsibility for this policy. The Compliance Officer acts as the designated point of contact for any questions, concerns, or reports.

Bribery and corruption are strictly prohibited at Stonebridge University.

• No employee, student, or representative may offer, promise, give, request, or accept any form of bribe.
• We will not tolerate attempts to improperly influence decisions by offering financial or non-financial advantages.
• All employees must decline opportunities that would compromise the university’s ethical standards.

Violations of this policy may result in disciplinary action, termination, and possible criminal prosecution.

Bribery is offering, giving, receiving, or soliciting something of value to influence an action or decision improperly. A bribe can occur even if it fails.

Examples of bribes include:

• Cash or cash equivalents (gift vouchers, debt forgiveness).
• Gifts, meals, entertainment, or travel that are excessive or not proportionate.
• Political or charitable contributions made to gain undue influence.
• Job offers, internships, or benefits to relatives of officials or partners.

Corruption is dishonest or fraudulent conduct by those in power, typically involving bribery.

Stonebridge University may be held liable for the actions of third parties acting on its behalf.

• All consultants, contractors, recruitment agents, and other partners must comply with this policy.
• Third parties must be clearly informed of Stonebridge University’s anti-bribery expectations.

Interactions with government officials require special care.

• Reasonable hospitality may be permitted where legally allowed, but anything excessive or intended to influence must be avoided.
• The Compliance Officer must approve all offers of gifts, travel, or entertainment involving government officials.

So-called “facilitation” or “grease” payments, made to speed up routine government actions, are illegal under UK law and strictly prohibited at Stonebridge University.

• Employees and representatives must immediately report any suspected bribery to their line manager or the Compliance Officer.
• Concerns may also be raised anonymously through the university’s Whistle blower Reporting Mechanism.
• Retaliation against anyone reporting a concern in good faith will not be tolerated.

• All staff must receive training on this policy as part of induction and refresher sessions.
• Compliance will be regularly reviewed by the University’s Audit and Risk Committee.
• Any breach of this policy will result in disciplinary action.

Stonebridge University is committed to maintaining the highest standards of honesty, fairness, and accountability. Bribery and corruption undermine trust, academic integrity, and our mission to deliver quality global education.