Kensington Academic Pathways Anti-bribery and Corruption Policy

This policy outlines the anti-bribery and corruption policies of Kensington Academic Pathways and the duties of its employees and establishes its zero-tolerance policy for bribery and corruption. It also serves as source and reference of knowledge, information and assistance for Kensington Academic Pathways employees to use and help them in recognising and dealing with bribery and corruption situations, as well as understanding their roles and obligations.

Policy statement

Kensington Academic Pathways is dedicated to doing business in an ethical, honest, and fair manner, as well as applying effective anti-bribery and anti-corruption policies. This includes wherever and in whichever country we operate and we are committed to obeying appropriate anti-bribery and anti-corruption laws and acting with integrity in all business interactions and partnerships.

Kensington Academic Pathways shall abide by all anti-bribery and anti-corruption laws in all locations in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, in regards to our conduct both at home and abroad.

Bribery and corruption are punishable by up to ten years in prison and a fine. If our company is found to have participated in corrupt actions, we may face an unlimited fine, be barred from bidding on public contracts and face serious damage to our reputation. As a result, we take our legal obligations very seriously.

Those covered by the policy

This anti-bribery policy applies to all employees, regardless of level or grade, including consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees (within or outside of the UK).

Every individual or organisation with which our company communicates and works is referred to as a third-party in the context of this policy. This includes but is not limited to clients, customers, suppliers, distributors, business contacts, agents, advisers and representatives are all covered.

Any deal our company enters into with a third party is controlled by clear contractual terms, which include specific provisions requiring the third party to follow anti-bribery and anti-corruption minimum standards and practices.

Definition of bribery

Bribery is described as promising, offering, seeking, agreeing, receiving, accepting, or soliciting a reward, incentive, or something of value in order to persuade or influence an action or decision. This also includes any inducement, prize, or valuable object/item presented to another person in exchange for a financial, contractual, regulatory, or personal benefit is considered a bribe.

Bribery is not limited to the act of giving a bribe. When a bribe is proposed and accepted, the person is breaking the law.

Bribery is against the law. Bribery is prohibited in any form, whether it is done directly, passively (as indicated above), or through a third party (such as an agent or distributor). They must not accept any form of bribe, and they must seek clarification from the company’s compliance manager if they are unsure if anything is a bribe, a gift, or an act of hospitality.

It is not acceptable to or for:

a member of staff (or someone on their behalf) to: make, promise to make, or offer a money, gift, or hospitality with the expectation or hope of receiving a benefit for Kensington Academic Pathways, or to reward an advantage already received;

accept a gift, payment or hospitality from a third party that they are aware of or believe is being provided in the hopes of gaining an advantage or business advantage;

Threaten or retaliate against an employee or coworker who has refused to engage in bribery or has expressed concerns about the policy.

Facilitation Payments and Kickbacks

Facilitation payments are a type of bribery intended to speed up or ease a public official’s performance in connection with a routine governmental procedure, rather than to earn or keep business or any other illegitimate economic advantage. Low-level government officials frequently seek facilitation payments in order to provide a level of service that would otherwise be expected.

Kensington Academic Pathways does not make or take any form of facilitation payments or “kickbacks” (Payments made in exchange for a business benefit or favour are known as kickbacks).

Employee Responsibilities

It is your obligation as a Kensington Academic Pathways employee to read, understand, and comply with this policy. Any behaviour that could lead to or suggest a breach of this policy must be refrained from by all workers.

If you have reason to believe or suspect that an instance of bribery or corruption has  occurred or will occur in the future that breaches this policy, you must notify your manager.

Employees who break this policy will face disciplinary action, which might include dismissal if they are found guilty of gross misconduct. We reserve the right to terminate our contractual relationship with other workers if they breach this policy.

How to raise a concern

If you have reason to believe bribery or other corrupt activity has occurred, you should report it immediately. If you’re unsure whether a particular action or behaviour is bribery or corruption, talk to your manager as soon as feasible. Whistleblowing will be taught to Kensington Academic Pathways employees to voice concerns immediately and in a confidential manner.

What to do if you are a victim of bribery or corruption

If you are offered a bribe by a third party, are requested to make one, suspect that this may happen in the future, or believe you are a victim of another sort of illegal behaviour, it is critical that you notify your management as soon as possible..


Kensington Academic Pathways understands you may be concerned about the implications if you refuse to take or give a bribe, or if you express a concern about suspected bribery or corruption. Even if investigation proves that they were mistaken, Kensington Academic Pathways will stand behind anyone who raises concerns in good faith in accordance with our policy.

Kensington Academic Pathways will ensure that no one suffers detrimental treatment as a result of refusing to take or pay a bribe or engaging in other corrupt activities, or because they voiced a concern about bribery or corruption.

Detrimental treatment includes disciplinary action, mistreatment, or other unfavourable treatment in response to a person’s anxiety connected with raising a concern. If you have reason to believe you’ve been treated unfairly as a result of your concern or refusal to accept a bribe, you should inform your manager.

Record Keeping

Kensington Academic Pathways will keep thorough and accurate financial records, as well as enough internal controls to provide verification of all payments made. We will declare and keep a written record of the amount and reason for any hospitality or gifts we receive or give, and we will understand that gifts and acts of hospitality are subject to management examination.

Monitoring and reviewing

On a regular basis Kensington Academic Pathways will evaluate the policy’s effectiveness and check its implementation, taking into account its suitability, adequacy, and effectiveness.
Any improvements that are mentioned will be incorporated as soon as possible. Internal control systems and processes will be audited on a regular basis to ensure that they are effective in combating bribery and corruption.

Employees are invited to give comments on the policy and make suggestions for improvements. All comments, suggestions, and questions should be directed to the manager.

This policy is not part of an employee’s employment contract and can be changed at any time.