Trust in Learning Academies
Bristol
Anti-Bribery Policy
Leadership Responsibility:
Chief Executive (TiLA)
Finance & Operations Director (TiLA)
To be ratified by: TiLA Board
Last ratified: February 2013
Review due: January 2014
Signed:
1 of 4 Trust in Learning : Trust in Success
1. Introduction
Trust in Learning [Academies] is committed to carrying out its academic and
business activities in an honest, transparent and ethical manner within the UK
and Internationally. Bribery is illegal and has no place in our organisation. The
2010 Bribery Act creates a number of new bribery and corruption offences.
Sanctions for these offences include up to 10 years imprisonment. The
Academy’s stance on bribery is one of zero tolerance.
2. Aims
The aims are to 




Ensure that everyone is aware of what constitutes bribery
Maintain high standards of business practice
Demonstrate a high level of integrity in our business transactions
Protect our reputation
Ensure that the public money is spent for the purposes intended by
Parliament
3. Scope
This policy applies to all members of staff at all levels/grades, including senior
managers, directors, consultants, agency staff, volunteers or any other person
associated with the Academy. It covers permanent, fixed term and temporary
employees.
4. Values, Principles and Standards
Bribery is an inducement or reward offered, promised or provided in order to
gain commercial, contractual, regulatory or personal advantage. Acts of bribery
or corruption are designed to influence the individual in the performance of their
duty and incline them to act dishonestly.
It is an offence under the act to:  Offer a bribe [whether cash or other inducement whatever the size]
 Receive a bribe
 Consent or connive to the commission of a bribery offence by anyone
associated with the Academy.
2 of 4 Trust in Learning : Trust in Success
5. Objectives
 To prevent bribery throughout the organisation
 Compliance with the Bribery Act 2010
 Compliance with the Charities Act and Academy legislation
6. Communication
 If there is any doubt as to whether an action might constitute bribery the
matter should be referred to the Chief Executive for guidance.
 The Trust in Learning Board will notify the schools when a new policy is
added or an existing policy is reviewed.
 Schools must notify the Trust in Learning Board if they have created a new
policy or amended an existing policy.
 This policy is one of a suite of policies and is listed under the main policy
matrix that shows the full list of policies that are available.
 The policy is available on a drive that is accessible to all staff.
 All staff are notified when a policy is updated or a new policy is added to
the portfolio.
 The staff induction process covers policies and procedures together with
the on line access instructions.
7. Responsibilities and Accountabilities
 All staff have a responsibility to prevent, detect and report bribery. Relevant
guidance will be available to assist staff in fulfilling this duty.
 Any suspicion of bribery or attempted bribery committed by or against an
employee, agent or other party acting on behalf of the Academy must be
reported immediately to the Chief Executive.
 The Whistleblowing Policy is in place to protect anyone reporting
reasonable suspicions.
 The Trust in Learning Board is responsible for ensuring that each school
complies with legislation and that this policy and its related procedures are
implemented.
 The Head Teacher is responsible for the implementation of this policy and
for ensuring that all staff are aware of this policy.
 The Head Teacher must ensure that this policy is covered during the staff
induction process.
3 of 4 Trust in Learning : Trust in Success
8. Monitoring and Review
 The effectiveness of this policy is evaluated in the annual Academy
Improvement Plan.
 Targets are set if appropriate within the Improvement Plan.
 Policies reviews are on an annual basis and have a major review every three
years. The next major review date is stated at the start of this policy.
 Any complaints regarding this policy or the operation of this policy will be
handled via the Complaints Procedure Policy.
 Any complaint against or by a member of staff will be covered by reference
to the Discipline, Conduct and Grievance Policy.
.
4 of 4 Trust in Learning : Trust in Success