The University has a commitment to observe the highest standards of probity and integrity in all its

business transactions. Any member of University staff responsible for purchasing or involved in a

procurement or tender process must promote this commitment by:

• being fair, efficient, firm and courteous;
• maintaining the highest possible standard of integrity in all business relationships;
• acquiring and maintaining current technical knowledge;
• achieving appropriate professional standards in the management of contracts;
• fostering appropriate standards of professional competence amongst those for whom they are responsible;
• complying with the law, guidance on professional practice and contractual obligations;
• declaring any personal interest which may affect or be seen by others to affect impartiality;
• respecting the confidentiality of information received in the course of duty and ensuring that information given in the course of duty is honest and clear; and
• responding promptly, courteously and efficiently to suggestions or enquiries, including handling Freedom of Information obligations according to organisational policies. 

The University’s approach to Anti‐Bribery, Gifts and Hospitality is set out in the University’s Financial Regulations and GCU Financial Procedures.

The University is required to ensure that it is in compliance with the Bribery Act 2010. It is a corporate offence to fail to prevent bribery. Full guidance and information on the procedures that are in place are available from the Anti‐Bribery Policy

Gifts

All staff should conduct themselves with integrity, impartiality and honesty at all times and should maintain high standards of propriety and professionalism.  The University does not permit its staff to accept or to offer personal benefits in order to procure services or gain influence. To do so is not only unacceptable; it is also illegal in terms of the Bribery Act 2010 which carries significant penalties. The Gifts and Hospitality Policy provides guidance to staff, students and governors on the action that should be taken in the event that:  they are offered gifts and/or hospitality by external organisations;  or have personal, financial or other beneficial interests in any transaction between the University and a third party;   or where they are in a position which requires them to offer gifts/hospitality.

Hospitality

Members of University Court and staff may accept meals and equivalent hospitality only in the normal course of business and only when the hospitality is of a reasonable level. Reasonableness should take into account the nature of the event, and the University representative should ensure 8 the hospitality does not compromise them in any way. In general a meal and refreshment would be regarded as acceptable.

Where a member of staff considers that there is an actual or potential conflict of interest arising from existing or prospective commitments or involvement, he or she should seek advice from the Head of Department and should formally declare any source of potentially conflicting interest as instructed in the Financial Procedures and Financial Regulations.

Potential conflicts of interest shall include:

• the member of staff or their immediate relative acting as a director or employee or providing services for reward to any organisation with whom the University has a business relationship.
• the member of staff or their immediate relative investing substantially in, or receiving benefits directly or indirectly from any organisation actually or potentially engaged in the supply of goods or services to the University.
• Where a member of staff has made such a disclosure they will not be permitted to take any part in the decision making process for a related tender or be involved in issuing a purchase order to the company in question.

The University is committed to delivering Contracts that demonstrate and meet its sustainable procurement objectives, driving through positive social, environmental and economic impacts wherever possible.

 The University operates under Sustain Supply Chain Code of Conduct which sets out its expected standards for its supply chain in social, ethical and environmental compliance.

Contracted suppliers are encouraged to complete the Sustain Supply Chain Code of Conduct to assist in achieving its objectives.