4.1. Scope
4.1.1. This policy applies to all staff and ‘associated persons’ (anyone acting on behalf of the University), including (but not limited to):
● employees and workers (whether casual, temporary, fixed-term, permanent or on open-ended contracts), agency workers, seconded workers, volunteers or interns;
● associated persons, including (but not limited to);
● agents, contractors, associates, consultants, third-party representatives and business partners, suppliers, donors, sponsors , or any other person associated with the University wherever located;
● external members of Council and University committees, panels or boards if they perform services for or on behalf of the University;
● researchers and academic visitors whether self-funded or employed by other entities (such as other funders, universities or Oxford colleges), and retired members of staff, if they perform services for or on behalf of the University;
● subsidiary companies and joint venture entities where the University wholly owns or controls the entity unless separate policies have been formally approved and adopted by the Boards of those companies and endorsed by Council’s General Purposes Committee. This covers the joint venture partners and, where applicable, those companies conducting services on behalf of the joint venture;
● societies of the University of Oxford (e.g. Reuben College), but not other colleges, which have their own policies; and
● students (i.e. anyone who has a contract for study with the University) when employed by or otherwise acting on behalf of the University, e.g. as members of committees or when representing the University in sports or other competitions.
4.1.2. This policy has been adopted by Council and applies throughout the University, apart from Oxford University Press which has its own policy and procedures. The policy applies to University operations in the UK and in any other country. Where there is a difference between the provisions of this policy and the law or regulations in another jurisdiction, the University will uphold the stricter provisions.
4.2. Responsibilities
4.2.1. Council is responsible for the administration of the University and for the management of its finances and assets and for setting the University policy to combat bribery and corruption. It is also responsible to the Office for Students for meeting its conditions of registration, which include operating comprehensive corporate risk management and control arrangements.
4.2.2. The Registrar is responsible for ensuring that this policy is implemented and maintained, and that appropriate explanatory guidance is provided.
4.2.3. Every member of staff and associated person who acts on behalf of or provides services to the University (as set out in the “Scope” section above) is responsible for ensuring that they:
● act in a fair and impartial manner without favouritism or bias;
● understand their responsibilities under this policy and related policies and comply with these at all times;
● guard against the commission of bribery by or on behalf of anyone associated with the University;
● have due regard to the steps taken by the University to prevent bribery (section 5); and
● report any suspicion of bribery or other concerns (section 7).
4.2.4. Members of staff involved in higher risk activities (see 2.2 above) in the UK or overseas are responsible for ensuring that they review relevant guidance, carry out appropriate risk assessments and bring this policy to the attention of relevant associated persons.
4.2.5. Heads of Division, Heads of Department (including Faculty Board Chairs), and Heads of University Services (UAS and GLAM) are responsible for ensuring that staff within their divisions, departments and sections (as appropriate), affected students, and other associated persons are made aware of this policy and associated explanatory guidance.
4.2.6. The Boards of Directors of majority owned/controlled joint ventures and wholly owned/controlled subsidiaries are responsible for ensuring that this policy – or an alternate policy that is endorsed by Council’s General Purposes Committee – is implemented and maintained within those companies, and that staff and other associated persons are made aware of the policy and associated explanatory guidance.
4.2.7. The Boards of Directors of equal and minority joint ventures are expected to act in accordance with this or equivalent policies.
