INTRODUCTION
 
Bribery is a criminal offense. Athena Global Education prohibits any form of bribery. We require compliance, from everyone connected with our institutional activities, with the highest ethical standards and anti-bribery laws applicable. Integrity and transparency are of utmost importance to us and we have a zero-tolerance attitude towards corrupt activities of any kind whether committed by Athena Global Education employees, officeholders, or third parties acting for or on behalf of the group.
 
POLICY
It is prohibited, directly or indirectly, for any employees, officeholders, or person working on our behalf to offer, give, request or accept any bribe i.e. gift, loan, payment, reward or advantage, either in cash or any other form of inducement, to or from any person or company in order to gain commercial, contractual or regulatory advantage for Athena Global Education, or in order to gain any personal advantage for an individual or anyone connected with the individual in a way that is unethical. It is similarly prohibited for any employees, offer holders or persons working on behalf of Athena, to request or accept any form of inducement to depart from normal Athena operating procedures and
policies, including those relating to the admission of students.

If Athena suspects that a member of staff or officeholder has committed an act of bribery or attempted bribery, an investigation will be carried out and, in line with our disciplinary procedure where appropriate, action may be taken against the member of staff or officeholder which may result in their dismissal or the cessation of their office, or of our contractual arrangements
with a company.

If as an employee, office holder, or person working on behalf of Athena, a member of staff suspects that an act of bribery or attempted bribery has taken place, even if the member of staff is not personally involved, s/he is expected to report this to the Bursar (or the President). They may be asked to give a written account of events. 

GIFTS AND HOSPITALITY

Gifts and Hospitality (and Entertainment) include the receipt or offer of gifts, meals, tokens of appreciation, invitations, and tickets to events and functions in matters connected with our business. These are acceptable provided that they fall within reasonable bounds of value and occurrence, subject to the further provisos listed and described below

Gifts and Hospitality
cannot be accepted from third parties taking part in a procurement process and seeking to do business with Athena Global Education
cannot be accepted if it involves an offer for something in return
cannot be accepted if it involves cash or equivalent
cannot be accepted if it involves sexual or other inappropriate activity
Employees need to consider when offered a Gift or a Hospitality:
what is the intent of this offer?
How would I justify it or explain it?
Am I comfortable accepting it?
How does it affect my independence?
Clearly, gifts and hospitality can amount to real or perceived bribery and caution should always be exercised. It is down to the employee to make this judgment but if there is any doubt about the propriety of hospitality, it should not be accepted or offered.

Acceptance of Gifts and Hospitality:
Employees accepting G&H should declare the receipt to the Procurement Department who will review (with payroll) for any taxable ‘benefit in kind’. Staff must also notify their line manager.
All employees of the university have a responsibility to help detect, prevent and report instances of bribery and suspected bribery, this extends to all suspicious activity or wrongdoing. The University is committed to a safe, reliable, and confidential way of reporting suspicious activity. If you are concerned, know or suspect that bribery is taking place, see your line manager in the first instance, or if this is not possible or advisable, contact the Financial Controller or Procurement.

Anti-Bribery Whistleblowing Policy
The Whistleblowing Policy is designed to allow staff, student and all members of Athena Global Education  to raise at high level concerns which they believe in good faith provides evidence of malpractice or impropriety. Individuals discovering or suspecting malpractice, impropriety or wrongdoing are able to disclose the information without fear of reprisal. A disclosure in good faith which is subsequently not confirmed, will not lead to action against the person making the disclosure.