1. Introduction and Statement of Commitment
Learnera LTD (hereinafter referred to as “the Company”) is committed to conducting its business operations with the highest standards of integrity, transparency, and accountability. The Company adopts a zero-tolerance approach to all forms of bribery and corruption and is committed to full compliance with the UK Bribery Act 2010, relevant common law, and any applicable anti-corruption legislation in the jurisdictions in which it operates.
This Policy sets out the responsibilities of the Company, its employees, officers, contractors, agents, and associated third parties in upholding these principles and provides guidance on recognising, preventing, and reporting corrupt behaviour.
2. Purpose
The primary objectives of this Policy are to:
Prevent, detect, and respond to bribery and corruption risks within the Company’s operations and partnerships.
Ensure compliance with statutory obligations under the Bribery Act 2010.
Safeguard the Company’s reputation, stakeholders, learners, and commercial interests.
Promote an organisational culture of lawful and ethical conduct across all eLearning, consultancy, content development, and business services.
3. Scope and Applicability
This Policy applies to:
All employees (permanent, fixed-term, temporary, or freelance).
Company directors and officers.
External consultants, instructional designers, sales agents, affiliates, platform vendors, and resellers.
Any third party acting on behalf of or representing the Company, including in international contexts.
4. Legal Framework: Bribery Act 2010
Under the UK Bribery Act 2010, the following offences are criminal:
Offering, promising, or giving a bribe (Section 1).
Requesting, agreeing to receive, or accepting a bribe (Section 2).
Bribing a foreign public official (Section 6).
Failure of a commercial organisation to prevent bribery (Section 7).
The Company may be held criminally liable for acts of bribery committed by its associated persons unless it can demonstrate it had adequate procedures in place to prevent such conduct.
5. Definitions
Bribe: A financial or other advantage offered, promised, given, requested, or received to induce or reward improper performance of a function or activity.
Facilitation Payment: A minor payment made to expedite routine government or administrative actions. These are strictly prohibited by the Company, regardless of jurisdiction.
Third Party: Any individual or organisation the Company interacts with, including clients, learners, vendors, service providers, regulators, and government bodies.
Improper Performance: Failure to act in good faith, impartially, or in accordance with a position of trust.
6. Prohibited Conduct
All forms of bribery and corrupt practices are strictly prohibited, including but not limited to:
Offering or accepting bribes, kickbacks, or inducements in any form.
Providing gifts or hospitality with the intent to improperly influence business decisions.
Offering educational benefits, discounts, endorsements, or certifications in exchange for favour or contract award.
Using third parties or intermediaries to facilitate corrupt activities.
7. Gifts, Hospitality, and Promotional Expenditure
Gifts and hospitality are permissible only where they are:
Reasonable, proportionate, and lawful.
Not intended to secure any improper business or educational advantage.
In line with the Company’s Gifts and Hospitality Register policy.
All gifts or hospitality exceeding £50 in value must be disclosed to and approved by the Compliance Officer. Lavish or excessive entertainment, travel, or accommodation offers are strictly prohibited.
8. Due Diligence and Third-Party Risk Management
The Company will undertake appropriate due diligence before engaging with third parties, including:
Background checks on business partners, vendors, and affiliates.
Inclusion of anti-bribery and anti-corruption clauses in all contracts and service-level agreements.
Ongoing monitoring of third-party performance and compliance.
The Company reserves the right to terminate any business relationship with immediate effect if bribery or corruption is suspected or proven.
9. Roles and Responsibilities
Board of Directors:
Ensure strategic oversight of anti-bribery compliance.
Approve the Policy and its implementation measures.
Compliance Officer:
Oversee the implementation, training, and enforcement of this Policy.
Maintain the Gifts and Hospitality Register.
Investigate and respond to any reported violations.
Employees and Associated Persons:
Comply fully with this Policy and applicable laws.
Report any suspicions or incidents of bribery or unethical conduct immediately.
10. Reporting Mechanism and Whistleblower Protection
All employees and third parties are encouraged to report:
Any suspected breaches of this Policy.
Any concerns regarding unethical or unlawful behaviour.
Reports may be made confidentially to:
The line manager or Compliance Officer.
Through the Company’s Whistleblowing Procedure (which ensures anonymity and protection from retaliation).
The Company strictly prohibits victimisation of any individual who reports concerns in good faith.
11. Training and Awareness
All new employees and contractors must complete mandatory anti-bribery training as part of their induction.
Refresher training will be conducted annually and as needed, based on role or jurisdictional risk.
The Company will issue updates and guidance on relevant legal and regulatory developments.
12. Monitoring, Auditing and Review
The Compliance Officer will conduct periodic audits and assessments to ensure the effectiveness of this Policy.
Internal controls will be reviewed regularly to mitigate risks.
This Policy will be reviewed annually by the Compliance Officer and the Board, or sooner if required by legislative or operational changes.
13. Sanctions and Disciplinary Measures
Breach of this Policy by any employee, officer, or agent of the Company will result in:
Disciplinary action up to and including dismissal.
Potential civil and/or criminal prosecution under the Bribery Act 2010.
Termination of contracts or relationships with third parties found in breach.
Approved by: Nigel Long
Position: Compliance Manager
Date Approved: 01/01/2025
Next Review Date: 01/01/2026