Bribery, Fraud and Corruption Policy

1. Introduction 

Education Buying Group is committed to embedding a zero-tolerance approach to fraud, bribery and corruption risks and will ensure that appropriate action is taken to embed a culture where the highest professional standards are maintained to protect the integrity and reputation of ourselves and our users. 

Education Buying Group encourages anyone having reasonable suspicions of fraud, bribery and/or corruption, to report them to us immediately. 

2. Procurement 

Procurement, whether for the private or public sector, remains one of the greatest risk areas for potential bribery, fraud and corruption. 

Education Buying Group Ltd takes the offence of bribery, fraud and corruption seriously. All Education Buying Group and (our procurement partner) staff must be aware of the potential for bribery, fraud and corruption before, during and after a procurement process and perform their duties in accordance with Education Buying Group Policies and the CIPs (Chartered Institute of Procurement and Supply) Professional Code of Ethics and Code of Conduct. 

The Contract Manager must comply with the all Education Buying Group Staff Policies and Procedures and Codes of Conduct and must not invite or accept any gift or reward in respect of the award or performance of any contract.  It will be required for the Contract Manager to prove that anything received was not received corruptly.  High standards of conduct are obligatory, and corrupt behaviour will lead to dismissal and is potentially a crime. 

3. Procurement Process 

Any Request For Quote (RFQ) or Invitation To Tender (ITT) process must set out provisions for tenderers/candidates to raise concerns over potential fraud and corruption. This is contained in the ‘Instructions to Tenderers’ section of the ITT/RFQ documents. Should a bidder raise a concern then the procurement process must not proceed further and advice from the Director of Procurement must be obtained immediately. 

Where it is deemed a medium-high risk area the request of adequate Bribery policy provisions and statements must form part of the ‘selection stage’ evaluation of tenderers and candidates. Education Buying Group should reserve the right to disqualify any tenderer or candidate that has been found to have breached Bribery policies or convicted of fraud and corruption or have committed an offence under the Bribery Act 2010 and/or under the Prevention of Corruption Acts 1889 to 1916. 

The Bribery Act 2010 provides for the following offences that have a specific relevance for public procurement, namely: 


  • Bribing a person to induce or reward them to perform a relevant function improperly; 
  • Requesting, accepting or receiving a bribe as a reward for performing a relevant function improperly 
  • Failing to prevent bribery 


Adequate provision will be made in the contract terms and conditions where Bribery, Fraud and/or Corruption are deemed to be a risk. Such clauses may include for example: 

“Education Buying Group may terminate this contract and recover all its loss if the Contractor, its employees or anyone acting on the contractor’s behalf do any of the following things:  

a)               Offer, give, or agree to give anyone any inducement or reward in respect of this or any other Education Buying Group contract (even if the contractor does not know what has been done).

b)               Commit an offence under the Prevention of Corruption Acts 1889 to 1916.

c)               Commit any fraud in connection with this or any other 2buy2 contract whether alone or in conjunction with Education Buying Group employees or representatives.

Any clause limiting the contractor’s liability shall not apply to this clause.” 

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4. Reporting

Legal advice must be obtained where there is suspected corrupt, fraudulent or criminal activity with a supplier/contractor or client/customer. Where it involves another Education Buying Group staff member staff must follow the Education Buying Group Whistleblowing Policy at all times which can be found on the Education Buying Group Website and notify the appropriate person according to the Whistleblowing Policy at the earliest opportunity.