IV. Unacceptable Acts

 

It is not acceptable for Global Family or anyone associated with Global Family, including actual and potential students, customers, suppliers, distributors, business contacts, partners, agents, and government and public bodies (including their advisors, representatives, officials, politicians, and political parties), to:

 

• Give, promise to give, or offer a payment, gift, or hospitality with the expectation that a business advantage will be received, or to reward a business advantage already given;

• Give, promise to give, or offer a payment, gift, or hospitality to a government official, agent, or representative to “facilitate” or expedite a routine procedure or approval process;

• Accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them;

• Accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by Global Family in return;

• Threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or

• Engage in any activity that might lead to a breach of this policy.

 

V. Facilitation Payments and Kickbacks

 

Global Family does not make, and will not accept, facilitation payments or “kickbacks” of any kind. If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for. Ask for a receipt which details the reason for the payment. If you have any suspicions or questions regarding a payment, please raise these with the Director. All workers should avoid activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.

 

VI. Gifts and Hospitality

 

This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality (given and received) to or from third parties for legitimate purposes, such as building relationships, and improving our image or reputation. The giving and receipt of gifts is not prohibited, if the following requirements are met:

 

• It complies with Global Family’s Financial Policies and Procedures, and where required, is reported to the appropriate person.

• It is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits, for example during contractual negotiations or a tender process.

• It complies with local law.

• It is given or received in Global Family’s name, not in your name.

• It is appropriate in the circumstances and not unduly lavish or extravagant.

• It is not given or received in cash (or a cash equivalent).

• It is given openly, not secretly.

• It is not offered to, or accepted from, government officials or representatives, politicians, or political parties without the prior approval of the Director.

 

VII. Donations

 

Global Family does not make contributions to political parties. We only make charitable donations that are legal and ethical under local laws and practices. No donation must be offered or made without the prior approval of the Director.

 

VIII. Your Responsibilities

 

You must ensure that you read, understand, and comply with this policy. The prevention, identification, and reporting of corruption, bribery, fraud, and other financial irregularity are the responsibility of all those working for or associated with Global Family. All actual and potential students, customers, suppliers, distributors, business contacts, partners, agents, and government and public bodies (including their advisors, representatives, officials, politicians, and political parties), are required to avoid any activity that might lead to, or suggest, a breach of this policy.

 

IX. Record Keeping

 

Global Family keeps financial records and maintains appropriate internal controls which will evidence the business reasons for making payments to third parties. All workers must declare and keep a written record of all hospitality or gifts accepted or offered. You must also ensure that all expenses related to hospitality, gifts, or expenses incurred to third parties are submitted in accordance with this policy. All accounts, invoices, and other records relating to dealings with third parties, including supplies and customers, should be prepared with accuracy. Accounts must not be kept “off book” to facilitate or conceal improper payments.

 

X. Raising a Concern

 

Workers are encouraged to raise concerns about any issue or suspicion of malpractice as early as possible. If you are unsure if an act constitutes corruption, bribery, fraud, and other financial irregularity, the issue should be raised with the Director, and if the Director is the subject of the issue, suspicion, or accusation, the issue should be raised with the Board of Directors.

 

XI. If You Are a Victim of Corruption, Bribery, Fraud, or Other Financial Irregularity

 

If you are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe you are a victim of another form of financial irregularity, follow the procedures in Appendix 1.

 

XII. Protection

 

Workers who refuse to accept or offer a bribe, or those who raise concerns or report a wrongdoing, may be worried about repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy. Global Family is committed to ensuring that no-one suffers any detrimental treatment as a result of refusing to take part in bribery, fraud, or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment and you are:

 

• An employee or person external to the organisation, you should raise it formally with the Director.

• A student, you should raise it formally using the Complaints and Grievances procedures.

 

XIII. Training and Communication

 

Training on this policy is available to all workers to whom this policy applies. Our zero-tolerance approach to corruption, bribery, fraud, and other financial irregularity must be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and as appropriate thereafter.

 

XIV. Responsibility

 

Global Family’s Director has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The Director has primary and day-to-day responsibility for implementing this policy, for monitoring its use and effectiveness, and dealing with any queries on its interpretation. Management at all levels are responsible for ensuring those reporting to them are made aware of, understand, and comply with this policy. All workers are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.

 

XV. “Red Flags”

 

The following is a list of possible red flags that may arise and which may raise concerns about possible corruption, bribery, fraud, and other financial irregularity. This list is not intended to be exhaustive. If you encounter any of these “red flags” you must report it immediately.

 

• You become aware that a third party engages in, or has been accused of engaging in, improper business practices;

• You learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a “special relationship” with foreign government officials;

• A third party insists on receiving a commission or fee payment before committing to sign up to a contract with us, or carrying out a government function to process for us;

• A third party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;

• A third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business;

• A third party requests an unexpected additional fee or commission to “facilitate” a service or approval process;

• A third party demands lavish entertainment of gifts before commencing or continuing contractual negotiations or provision of services;

• A third party requests that a payment is made to “overlook” potential legal violations;

• A third party requests that you provide employment or some other advantage to a friend or relative;

• You receive an invoice from a third party that appears to be non-standard or customized;

• A third party insists on the use of side letters or refuses to put terms agreed in writing;

• You notice that we have been invoiced for a commission or fee payment that appears large given the service stated to have been provided;

• A third party requests or requires the use of an agent, intermediary, consultant, distributor, or supplier that is not typically used by or known to us;

• A third requests or requires the use of an agent, intermediary, consultant, distributor, or supplier and it is not clear what goods or services they will be supplying;

• You are offered an unusually generous gift or offered lavish hospitality by a third party;

• As a budget holder/manager you are asked to approve an expense claim which shows unaccustomed expenditure, possibly with no receipts;

• You have been asked to falsify or alter accounting/auditable records;

• You are offered money or a gift by a student or on a student’s behalf to “facilitate” a good mark in an assessment.

 

Appendix I: Response Plan

 

The following is intended to clarify the procedures for reporting suspected corruption, bribery, fraud, and other financial irregularity and how members of Global Family’s management should respond.

 

Individuals should raise concerns about the actions of a worker with their immediate manager without delay. If the concern relates to an individual’s immediate manager, the individual should raise it with their manager’s manager. The manager should either ask the individual to put their concern in writing or interview them and record their concerns in writing.

 

Global Family reserves the right to notify the police where it believes that a criminal offense has taken place. The Director and Board of Directors shall take appropriate action for the prevention of any further loss and for the recovery of any loss suffered, including legal costs where appropriate.