1. Document Control
Policy Owner: Principal / Director
Responsible Committee: Management Committee
Approval Authority: Principal / Director
Effective From: [Insert date]
Review Date: [Insert date – annually]
Version: 1.0
Applies To: All employees, contractors, associates, visiting lecturers, volunteers and any individual acting on behalf of Equra College London. This policy also applies to third parties where they provide services to the College or represent the College.
2. Purpose
Equra College London is committed to operating with integrity, transparency and strong financial stewardship. This policy sets out the College’s standards and controls to prevent, detect and respond to fraud, bribery and corruption. It aims to:
a. Protect students, staff, partners and the College from financial and reputational harm.
b. Set clear expectations and reporting routes for concerns.
c. Ensure prompt, fair and proportionate response to suspected wrongdoing.
d. Support a culture where ethical conduct is non-negotiable.
3. Scope
This policy applies to any activity connected to the College, including:
a. Admissions, enrolment and fee handling
b. Procurement and purchasing
c. Payroll and expenses
d. Partner and supplier relationships
e. Marketing, recruitment and agent activity
f. Gifts, hospitality and sponsorships
g. Funding, grants and donations
h. Student assessments and certification processes where financial influence is attempted
4. Definitions
Fraud: Dishonest conduct intended to make a gain, cause loss, or expose another to risk of loss.
Bribery: Offering, promising, giving, requesting or accepting an advantage to induce improper performance of a function or activity.
Corruption: Abuse of a position of trust for private gain, including bribery, conflicts of interest and improper influence.
Facilitation payment: An unofficial payment to secure or speed up a routine action. These are prohibited.
5. Policy Statement
Equra College London has a zero-tolerance approach to fraud, bribery and corruption. All staff and representatives must act honestly and must not:
a. Engage in fraudulent activity
b. Offer or accept bribes
c. Provide or accept improper gifts or inducements
d. Conceal wrongdoing
e. Misuse College funds, resources or authority
6. Responsibilities
6.1 All staff and representatives must:
a. Follow this policy and relevant procedures.
b. Report suspected wrongdoing promptly.
c. Co-operate with investigations.
d. Avoid conflicts of interest and declare them.
6.2 Principal / Director is responsible for:
a. Ensuring appropriate controls are in place.
b. Appointing an investigator where required.
c. Ensuring appropriate escalation and reporting.
6.3 Finance and administrative roles, where applicable, are responsible for:
a. Maintaining appropriate financial controls.
b. Keeping accurate financial records.
c. Ensuring appropriate authorisation routes are followed.
7. Prevention and Controls
The College will implement proportionate controls to reduce risk, which may include:
a. Clear authorisation limits for spending and procurement.
b. Separation of duties for payment approval where possible.
c. Transparent fee and refund processes.
d. Secure handling of cash where cash handling exists.
e. Audit trails for key financial decisions.
f. Supplier and partner due diligence where appropriate.
g. Staff training and awareness where needed.
8. Gifts, Hospitality and Sponsorship
8.1 General rule
Staff must not offer or accept gifts or hospitality that could influence decision making or create a perception of improper influence.
8.2 Acceptable gifts and hospitality
Low-value, occasional and transparent hospitality may be acceptable if it is:
a. Reasonable and proportionate
b. Not intended to influence a decision
c. Not linked to admissions, assessments, procurement or contracting decisions
d. Declared where required by College processes
8.3 Prohibited situations
Gifts and hospitality must never be accepted or offered where:
a. A decision is pending or expected
b. The gift is cash or a cash equivalent
c. The value is excessive
d. The circumstances are secretive or unusual
e. There is pressure, expectation or reciprocity
8.4 Sponsorship and donations
Sponsorship or donations must be accepted only where:
a. The purpose is legitimate and transparent
b. The source is appropriate
c. There is no expectation of improper influence
d. Documentation is maintained
9. Conflicts of Interest
All staff and representatives must declare conflicts of interest, including:
a. Personal relationships affecting admissions, recruitment or contracting decisions
b. Financial interests connected to suppliers, partners, students or applicants
c. External work that conflicts with College responsibilities
Where a conflict exists, the individual must step back from decision making and follow any direction given by the Principal / Director.
10. Reporting Concerns
Concerns should be reported promptly using the Whistleblowing routes, including where the concern involves:
a. Suspected fraud or theft
b. Improper payments or invoices
c. Bribery attempts
d. Improper inducements linked to admissions, grades or outcomes
e. Financial irregularities
If there is immediate risk or a serious incident, concerns should be escalated urgently.
11. Investigation and Response
11.1 Initial assessment
The College will assess the concern and determine whether immediate safeguards are needed.
11.2 Investigation
Investigations will be proportionate, evidence-based and fair. The College may review documents, systems records, communications and financial trails.
11.3 Outcomes
Where wrongdoing is identified, the College may take action including:
a. Disciplinary action
b. Termination of contracts
c. Referral to law enforcement
d. Recovery of losses
e. Reporting to partners or regulators where required
11.4 Confidentiality
Investigations will be handled confidentially as far as possible, subject to lawful disclosure obligations.
12. False Allegations
Reports made in good faith are protected even if not proven. Knowingly false or malicious allegations may result in action.
13. Monitoring and Review
This policy will be reviewed annually and after any significant incident to strengthen controls and learning.
14. Related Policies and Documents
a. Whistleblowing, Public Interest Disclosure and Ethical Reporting Policy
b. Staff Conduct, Recruitment and Professional Standards Policy
c. Student Enrolment Contract Policy and Procedure
d. Tuition Fees, Payments and Refunds Policy
e. Data Protection Policy
f. Information Security Policy
g. Data Breach Incident Response Procedure
h. Risk Assessment Policy and Template