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Anti-Bribery Policy

Conforming to UK Bribery Act, US FCPA, and global anticorruption standards

Anti-Bribery Policy

1. Purpose

This Policy establishes principles that must govern our conduct in order to:

  1. Conform to the UK Bribery Act, U.S. Foreign Corrupt Practices Act (FCPA), and similar anticorruption laws worldwide.
  2. More broadly, reinforce the intention and obligation to act honestly and ethically in all business dealings.

2. Scope of Policy

This policy applies to Uniadmit, its subsidiary companies, and all employees of Uniadmit and its subsidiaries globally. The policy concerning bribery applies to all business clients (such as HEI, FE staff, student clients, franchises, partners, landlords, contractors, & service providers... etc); and to government employees.

3. Responsibility

The compliance committee (the Global Directors and the Head of Compliance Armughan Malik) are the final authority to this policy. Armughan Malik is located in the London UK office and any queries or concerns on this policy can be directed to him.

4. Policy Statement

At Uniadmit, bribery is never permitted. We will not seek to influence others, either directly or indirectly, by offering, paying or receiving bribes or kickbacks, or by any other means that is considered unethical, illegal or harmful to our reputation for honesty and integrity.

While certain laws apply only to bribes to government officials (domestic and foreign); this Policy applies to non-government business partners, such as our university clients, partners, student clients and franchises as well.

5. What is Bribery and Corruption?

Bribery is offering, giving or receiving anything of value with the intention of inducing a person to act or to reward a person for having acted. It is important to understand that a corrupt act has occurred even if the bribe does not succeed or if a person authorizes a bribe but it is not paid.

"Anything of value" includes:

  • Cash, gift cards/certificates, stock, property and debt forgiveness.
  • Gifts, meals, entertainment and travel (must be proportionate and compliant).
  • Political or charitable contributions (when requested to obtain/retain business).
  • Job offers or internship awards (Compliance must be consulted first).
6. Third Parties

Companies cannot avoid liability by using third parties. We convey expectations to all consultants, agents, subcontractors, and representatives.

7. Government Officials

Hospitality acceptable with normal business contacts might not be allowable when government officials are involved. Standards are strict.

8. Facilitation Payments

"Grease payments" to speed up routine actions are prohibited. They are illegal under the UK Bribery Act and strictly banned by our policy.

9. Reporting Violations

If you are offered a bribe or have concerns regarding activities under consideration, please report it immediately to your manager or our compliance team.