RRC conducts its business in a legal and ethical manner. Tutors, management, employees, other staff and any other associated person acting on the companies behalf are responsible for acting honestly and with integrity by ensuring that their activities, interests and behaviours do not conflict with these obligations, regardless of their seniority
The Company is committed to the prevention of fraud and to the promotion of an anti-fraud culture. We operate a zero-tolerance attitude to fraud and require staff, students and our partners to act honestly and with integrity at all times and to report all reasonable suspicions of fraud.
RRC investigates all instances of actual and suspected fraud committed by staff, students, consultants, and other third parties and will seek to recover funds lost through fraud. Perpetrators will be subject to disciplinary and/or legal action.
The Senior Management team is responsible for developing, implementing and maintaining adequate systems of internal control to prevent and detect fraud. All individuals have a duty to prevent, detect and report suspected fraud. Whistleblowing concerns may be reported confidentially under the Whistleblowing policy detailed separately in the Employee Handbook.
The Fraud Act 2006 provides a framework within which there are three potential areas that an individual may be guilty of fraud if in breach. These are fraud by:
In (a) to (c) above, the individual is deemed to have committed a fraud if they make a false representation, fail to disclose information or abuse their position to:
All suspected or actual incidents of fraud allegedly perpetrated by individuals other than students or enquirers should be reported without delay to the SMT.
All suspected or actual incidents of fraud concerning a student or applicant to study should be reported without delay to the appropriate Awarding body who will advise on how to proceed and may treat the case as malpractice.
Where initial investigation provides reasonable grounds for suspicion of fraud, If the individual is an employee or student this may require the suspension (an employee with or without pay), of the person(s) alleged to have committed the suspected fraud.
Repayment of losses should be sought in all cases. The Company will, as necessary, consider seeking legal advice, for example on the freezing of the suspect’s assets in cases of substantial loss and on the recovery of losses and costs through the civil courts.
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.
We are committed to improving our practices to combat slavery and human trafficking. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and forms the slavery and human trafficking statement.
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.
We have zero tolerance to slavery and human trafficking within both the company and its supply chain. All interested parties to the business are expected to comply fully with modern slavery legislation.
The Senior Management team is responsible for developing, implementing and maintaining adequate systems of internal control to prevent and detect any forms of slavery. All individuals have a duty to prevent, detect and report suspected concerns regarding slavery and must report their concerns to a member of the Senior Management Team immediately. Whistleblowing concerns may be reported confidentially under the Whistleblowing policy detailed separately in the Employee Handbook.
The business has a commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
Our recruitment practices reinforce this policy by conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
The purpose of this policy is to establish controls to ensure compliance with all applicable antibribery and corruption legislation, and to ensure that the Company’s business is conducted in a socially responsible manner.
Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal or a breach of trust. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
It is our policy to conduct all of our business in an honest and ethical manner. We take a zero tolerance approach to bribery and corruption. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.
We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct both in the UK and overseas.
Bribery and corruption are punishable for individuals by up to ten years' imprisonment and a fine. If we are found to have taken part in corruption, we could face an unlimited fine, be excluded from tendering for public contracts and face damage to our reputation. We therefore take our legal responsibilities very seriously.
Who is covered by the policy?
In this policy, third party means any individual or organisation you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.
This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as employees in this policy).
This policy covers:
Bribes
Employees must not engage in any form of bribery, either directly or through any third party (such as an agent or distributor). Specifically, employees must not bribe a foreign public official anywhere in the world.
Gifts and hospitality
We appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.
This policy therefore does not prohibit normal and appropriate hospitality (given and received) to or from third parties and the giving or receipt of gifts, in accordance with these guidelines.
Normal and appropriate hospitality and gifts would include where the hospitality or gift:
It is NOT acceptable for you (or someone on your behalf) to:
If it is not appropriate to decline the offer of a gift, the gift may be accepted, provided it is then declared to the employee’s manager and donated to charity.
Within these parameters, local management may define specific guidelines and policies to reflect local professional and industry standards. Where this policy requires written approval to be given, the Compliance Manager shall put in place a process to maintain a register of all such approvals.
Facilitation payments and kickbacks
Facilitation payments are a form of bribery made for the purpose of expediting or facilitating the performance of a public official for a routine governmental action, and not to obtain or retain business or any improper business advantage. Facilitation payments tend to be demanded by low level officials to obtain a level of service which one would normally be entitled to.
Our strict policy is that facilitation payments must not be paid. We recognise, however, that our employees may be faced with situations where there is a risk to the personal security of an employee or his/her family and where a facilitation payment is unavoidable, in which case the following steps must be taken:
In order to achieve our aim of not making any facilitation payments, each business of the Company will keep a record of all payments made, which must be reported to the Compliance Manager, in order to evaluate the business risk and to develop a strategy to minimise such payments in the future.
Political Contributions
We do not make donations, whether in cash or kind, in support of any political parties or candidates, as this can be perceived as an attempt to gain an improper business advantage.
Charitable Contributions
Charitable support and donations are acceptable (and indeed are encouraged), whether of in kind services, knowledge, time, or direct financial contributions. However, employees must be careful to ensure that charitable contributions are not used as a scheme to conceal bribery. We only make charitable donations that are legal and ethical under local laws and practices. No donation must be offered or made without the prior approval of the Compliance Manager.
All charitable contributions should be publicly disclosed.
You must ensure that you read, understand and comply with this policy.
The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.
You must notify your manager OR the Compliance Manager as soon as possible if you believe or suspect that a conflict with or breach of this policy has occurred, or may occur in the future.
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve our right to terminate our contractual relationship with other workers if they breach this policy.
We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.
You must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review.
You must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure.
All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept "off-book" to facilitate or conceal improper payments.
You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries or concerns, these should be raised with your line manager OR the Compliance Manager.
What to do if you are a victim of bribery or corruption
It is important that you tell the Compliance Manager as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.
Employees who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the compliance manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using the company’s Grievance Procedure.
Our zero-tolerance approach to bribery and corruption must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and as appropriate thereafter.
The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
Management at all levels are responsible for ensuring those reporting to them are made aware of and understand this policy and are given adequate and regular training on it.
The Board will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption.
All employees are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing.