1. Policy statement
Luma Education Recruitment Ltd ("Luma") conducts its business honestly and ethically and has zero tolerance of bribery and corruption in any form. We comply with the Bribery Act 2010, under which it is an offence to offer, promise, give, request or accept a bribe, to bribe a foreign public official, or for a company to fail to prevent bribery by people acting on its behalf.
Much of our work is with schools, academy trusts and public sector frameworks, where the highest standards of probity are expected. This policy explains what that means in practice.
2. What is a bribe?
A bribe is any financial or other advantage offered, promised, given, requested or received to encourage someone to perform their role improperly, or as a reward for having done so. It does not have to be money: it can be a gift, hospitality, a favour, a job offer, a donation or a discount.
Examples that would breach this policy include:
- offering a school leader a gift, payment or hospitality to choose Luma as a supplier, extend a booking or accept a candidate;
- paying a commission or "finder's fee" to someone at a school for introductions or bookings;
- accepting payment or a favour from a candidate to put them forward ahead of others, or to overlook a missing check;
- offering anything of value to influence the outcome of a tender or framework evaluation;
- making a facilitation payment to speed up a routine process. These are bribes and are not allowed.
3. Gifts and hospitality
Reasonable and proportionate hospitality is a normal part of business, but it must never be, or look like, an attempt to influence a decision.
- Gifts and hospitality must be modest, infrequent, given openly and never in cash or a cash equivalent (such as vouchers).
- Nothing may be offered or accepted during a tender, framework evaluation or contract award process with the organisation concerned.
- Many schools and academy trusts only allow their staff to accept gifts of nominal value (often £25 or less). We respect those rules and never offer school staff anything above their own limit.
- Any gift given or received with a value of more than £50, or any hospitality worth more than £100 per person, must be approved by a director in advance (or reported within two working days if received unexpectedly) and recorded in our gifts and hospitality register. Gifts and hospitality from the same person or organisation are added together over a year.
- Our Code of Conduct also prohibits workers from giving gifts to, or accepting significant gifts from, individual children or families.
4. Conflicts of interest
Everyone covered by this policy must tell a director about any personal, family or financial interest that could conflict with their duties to Luma, for example a close relationship with someone involved in choosing a supplier at a school, or an interest in a competitor or supplier. Declared conflicts are recorded and managed, which may mean the person takes no part in the decision.
5. Working with third parties
We choose suppliers, partners and subcontractors carefully, carry out proportionate due diligence before working with them, and expect them to share our standards. Our contracts with suppliers and subcontractors require them to comply with anti-bribery laws, and we will end a relationship where we find bribery or corruption.
6. Political and charitable donations
Luma does not make political donations. Charitable donations are made openly, are approved by a director, and are never made to secure a business advantage.
7. Records
We keep accurate books and records of all payments, invoices, gifts, hospitality and expenses. No payment may be disguised or recorded inaccurately. Records are kept in line with our Data Retention Schedule.
8. Reporting a concern
If you are asked for, offered or suspect a bribe, or have any concern about corruption, report it straight away to Daniel Benson, Director (daniel.benson@lumaedrec.com, 0204 576 4344) or Tom Jackson, Director (tom.jackson@lumaedrec.com, 0204 576 4102). You can also use our whistleblowing procedure. Anyone who refuses to pay or accept a bribe, or raises a concern in good faith, will be supported and will not suffer any detriment.
9. Breaches
A breach of this policy by an employee or director may lead to disciplinary action, including dismissal. A breach by a worker, contractor or supplier may lead to the end of the relationship. Bribery is also a criminal offence and may be reported to the police or other authorities.
10. Training and review
All directors and staff are briefed on this policy at induction and at least once a year. This policy is reviewed every year, or sooner if the law or our business changes.