EduQuantica Ltd – Anti-Bribery and Corruption Policy

Policy statement

EduQuantica Ltd has zero tolerance for bribery and corruption, in the UK and every country where we or our sub-agents work. We would rather lose business than win it through a bribe.

Scope and the law

This policy applies to all directors, employees, contractors, sub-agents and anyone else acting for EduQuantica.

Under the UK Bribery Act 2010 it is an offence to:

• offer, promise or give a bribe;
• request, agree to receive or accept a bribe;
• bribe a foreign public official;
• for a company, fail to prevent bribery by anyone acting on its behalf (section 7).

The Act applies to conduct anywhere in the world. Individuals face up to 10 years in prison and unlimited fines; companies face unlimited fines. The only defence for a company under section 7 is having adequate procedures to prevent bribery, which this policy forms part of. We also comply with local anti-corruption laws in each country where we operate.

A bribe is any financial or other advantage, offered or given to make someone act improperly, or as a reward for doing so. It can be cash, gifts, hospitality, jobs, favours, discounts or donations.

What is prohibited

No one acting for EduQuantica may:

• offer or pay anything to university staff to secure offers, waive entry requirements, speed up decisions or increase commission;
• offer or pay anything to visa, embassy, police, exam centre or other officials, including "facilitation" or "speed-up" payments, even where locally common;
• pay anyone to provide, alter or overlook false documents, such as bank statements, certificates or English test results;
• offer students cash or gifts conditional on choosing a particular provider in a way that misleads them or breaches provider rules;
• accept anything from a student, family, sub-agent or supplier in return for preferential treatment;
• make political donations on behalf of EduQuantica;
• hide a payment, or record it falsely, in our accounts.

The only exception to facilitation payments is where someone faces a threat to their life, safety or liberty. Pay only what is needed to stay safe, then report it to the Compliance Officer within 24 hours.

Gifts and hospitality

Reasonable, proportionate hospitality is part of normal business, such as a working lunch with a university partner. It must never be given or accepted to influence a decision.

Gifts and hospitality must never be given during a live decision, such as an admissions review, a tender or a contract renewal.

Risks in student recruitment

Watch for these situations, which are common in our sector:

• a sub-agent or partner asks for cash payments, payment to a third party or payment in a different country;
• a university staff member suggests a "fee" to approve applications or bypass requirements;
• someone offers to secure visas or exam results for a payment;
• a sub-agent's commission claims are unusually high or lack supporting enrolments;
• a student family offers a gift to "make sure" the application succeeds.

Sub-agents and third parties

EduQuantica can be liable for bribes paid by sub-agents acting for us, so we:

• carry out due diligence on every sub-agent before onboarding, under our Sub-Agent Onboarding Policy;
• include anti-bribery clauses in every agreement, with the right to audit and to terminate for breach;
• pay commission only to the contracted business's verified bank account, in its registered country, against confirmed enrolments;
• review commission claims and unusual payment requests before paying them.

Reporting concerns

If you are offered or asked for a bribe, or suspect bribery, report it to the Compliance Officer, at compliance@eduquantica.com as soon as possible. You can report anonymously.

We will not tolerate retaliation against anyone who refuses to pay or take a bribe, or who raises a concern in good faith, even if it turns out to be mistaken. Staff are also protected by UK whistleblowing law.

Records

We keep accurate records of all payments, commission, gifts and hospitality. The gifts and hospitality register are reviewed by a director every quarter.

Training

All staff and sub-agents complete anti-bribery training at induction and every year after that. Staff in high-risk roles, such as partnerships and finance, get extra training.

Consequences of breach

• Staff who breach this policy face disciplinary action, which may include dismissal for gross misconduct.
• Sub-agents who breach it face immediate termination and withheld commission.
• We will report criminal conduct to the police or the Serious Fraud Office, and inform affected universities.