Anti-Bribery Policy

1. Policy Statement

Brussels College is committed to conducting all business activities with the highest standards of integrity, honesty, and ethical behavior. We have a zero-tolerance approach to bribery and corruption in all forms. This policy prohibits offering, giving, soliciting, or accepting any bribe, whether directly or indirectly, and regardless of whether it involves public officials, private individuals, or commercial entities.

2. Scope and Application

This Anti-Bribery Policy applies to:

• All Brussels College employees, including full-time, part-time, temporary, and contract staff
• All members of the Board of Governors and senior management
• Students representing Brussels College in official capacities
• Contractors, suppliers, consultants, and business partners acting on behalf of Brussels College
• All business activities, transactions, and relationships in all countries and jurisdictions

3. Legal Framework

Brussels College complies with all applicable anti-bribery and anti-corruption laws, including:

• Belgian Criminal Code (Articles 246-252) - Bribery of Public Officials
• UK Bribery Act 2010 (as applicable to international operations)
• US Foreign Corrupt Practices Act (FCPA)
• OECD Convention on Combating Bribery of Foreign Public Officials
• United Nations Convention Against Corruption

4. Definitions

4.1 Bribery

Bribery is the offering, promising, giving, accepting, or soliciting of an advantage (financial or otherwise) as an inducement for action that is illegal, unethical, or a breach of trust.

4.2 Types of Bribery

Type	Description	Example
Active Bribery	Offering or giving a bribe to influence a decision	Offering money to a government official to expedite a license approval
Passive Bribery	Accepting or soliciting a bribe in exchange for favorable treatment	Accepting payment from a student in exchange for higher grades
Facilitation Payments	Small payments to expedite routine government actions	Paying an official to process documents faster
Kickbacks	Returning a portion of funds as a reward for favorable treatment	Supplier paying a percentage back to procurement officer
Political Contributions	Donations made to influence political decisions	Funding a campaign in exchange for favorable regulation
Third-Party Bribery	Using intermediaries to make corrupt payments	Hiring a consultant to bribe officials on your behalf

4.3 Public Official

A public official includes:

• Government employees and civil servants
• Elected officials and politicians
• Employees of state-owned enterprises
• Officials of international organizations
• Political party officials
• Candidates for public office

5. Prohibited Conduct

5.1 Absolute Prohibitions

The following are strictly prohibited under all circumstances:

5.2 Specific Prohibited Activities

• Student Admissions: Accepting money or gifts in exchange for admission offers or preferential treatment
• Academic Integrity: Accepting bribes to alter grades, provide unauthorized assistance, or issue fraudulent certificates
• Procurement: Accepting payments from suppliers in exchange for awarding contracts
• Government Relations: Paying officials to obtain licenses, permits, or favorable regulatory treatment
• Research Misconduct: Manipulating research outcomes in exchange for funding or other benefits

6. Gifts and Hospitality Policy

6.1 Acceptable Gifts

Modest gifts and hospitality are permitted if they meet all of the following criteria:

• Given openly and transparently, not in secret
• Reasonable and proportionate in value (generally not exceeding €50)
• Not in cash or cash equivalents (gift cards, vouchers, etc.)
• Not given or received with the intention of influencing a decision
• Compliant with local laws and customs
• Documented and reported according to this policy

6.2 Examples of Acceptable vs. Unacceptable Gifts

Scenario	Acceptable?	Rationale
Promotional items (pens, notebooks) from a supplier	✓ Yes	Low value, promotional nature, no influence intended
Meal with a business partner to discuss collaboration (€40 per person)	✓ Yes	Reasonable hospitality, transparent, business purpose
Bottle of wine (€30) from a student as thanks after course completion	✓ Yes (with approval)	Low value, after completion, no influence on grades (report to supervisor)
Gift voucher (€100) from a supplier during contract negotiations	✗ No	Cash equivalent, high value, potential to influence decision
Luxury watch (€500) from a contractor	✗ No	Excessive value, inappropriate, potential bribery
All-expenses-paid vacation from a business partner	✗ No	Excessive value, clear intent to influence, inappropriate

6.3 Hospitality Guidelines

Business hospitality (meals, event attendance) is permitted when:

• It has a clear business purpose (networking, collaboration, discussion)
• It is proportionate and reasonable in value
• It does not create an obligation or expectation of reciprocity
• It is documented and reported if exceeding €100 per person

6.4 Gift Approval and Reporting

Gift/Hospitality Value	Required Action	Approval Required
Under €50	No action required (but may be documented)	No
€50 - €100	Must report to line manager within 5 days	Retrospective approval
Over €100	Seek prior approval from Vice Rector	Yes, before acceptance
Cash or equivalents (any amount)	Must be declined and reported immediately	Never acceptable

7. Due Diligence and Third Parties

7.1 Third-Party Risk

Brussels College may be liable for bribery committed by third parties acting on our behalf. We conduct due diligence on:

• Agents, consultants, and intermediaries
• Suppliers and contractors
• Joint venture partners
• Recruitment agencies and education agents
• Lobbyists and government relations consultants

7.2 Due Diligence Process

Before engaging a third party, the following steps are taken:

1. Risk Assessment: Evaluate the bribery and corruption risk associated with the relationship
2. Background Checks: Verify the third party's reputation, ownership, and compliance history
3. Contractual Provisions: Include anti-bribery clauses in all contracts requiring compliance with this policy
4. Monitoring: Conduct periodic reviews of third-party conduct and transactions
5. Red Flag Review: Investigate any suspicious activities or payments

7.3 Red Flags

Be alert to warning signs that may indicate bribery or corruption risk:

• Requests for cash payments or payments to third countries
• Unusually high commissions or fees without clear justification
• Lack of transparency about ownership or business activities
• Requests for false invoices or improper documentation
• Resistance to contractual anti-bribery provisions
• Close personal or family relationships with government officials

8. Reporting and Whistleblowing

8.1 Duty to Report

All staff and students have a duty to report suspected bribery or corruption immediately. Reports should be made even if you are uncertain or have incomplete information.

8.2 Confidentiality and Protection

Brussels College guarantees:

• Confidentiality: Reporter identities are protected to the extent permitted by law
• No Retaliation: Protection from retaliation, harassment, or adverse consequences for reporting in good faith
• Anonymous Reporting: Option to report anonymously through secure whistleblowing channels
• Investigation: Thorough and impartial investigation of all reports

8.3 Investigation Process

1. Receipt of Report: All reports are acknowledged within 48 hours
2. Preliminary Assessment: Determine scope, urgency, and investigation approach
3. Investigation: Gather evidence, interview witnesses, analyze transactions
4. Findings: Document conclusions and recommend corrective actions
5. Disciplinary Action: Take appropriate action if misconduct is confirmed
6. Follow-Up: Implement preventive measures and monitor compliance

9. Disciplinary Measures

9.1 Sanctions for Violations

Violations of this Anti-Bribery Policy will result in disciplinary action, which may include:

Stakeholder	Potential Consequences
Staff Members	Written warning, suspension, termination of employment, criminal referral
Students	Academic penalties, suspension, expulsion, revocation of qualifications
Third Parties	Contract termination, blacklisting, legal action, damages claims
Senior Management	Removal from position, dismissal, disqualification from governance roles

9.2 Criminal Prosecution

Bribery and corruption are criminal offenses. Brussels College will report serious violations to law enforcement authorities, which may result in:

• Criminal prosecution and imprisonment
• Substantial fines for individuals and organizations
• Confiscation of proceeds of corruption
• Debarment from public contracts
• Reputational damage and professional disqualification

10. Training and Awareness

10.1 Mandatory Training

• Induction Training: All new staff receive anti-bribery training within the first month
• Annual Refresher: All staff complete annual anti-bribery and ethics training
• High-Risk Roles: Enhanced training for procurement, finance, admissions, and senior management
• Student Awareness: Anti-bribery and academic integrity included in student orientation

10.2 Training Content

Anti-bribery training covers:

• Legal obligations and consequences of bribery
• Recognizing bribery and corruption red flags
• Gifts and hospitality guidelines
• Reporting procedures and whistleblowing protections
• Case studies and practical scenarios

11. Record Keeping and Financial Controls

11.1 Accurate Financial Records

Brussels College maintains accurate and complete financial records to prevent and detect bribery:

• All transactions are recorded accurately and in reasonable detail
• No off-the-books accounts or secret funds are permitted
• False or misleading entries are prohibited
• All expense claims are supported by valid receipts and documentation
• Regular audits are conducted to verify compliance

11.2 Internal Controls

• Segregation of duties in financial processes
• Authorization limits for expenditures and contracts
• Independent review and approval of transactions
• Regular reconciliation of accounts
• Secure access controls for financial systems

12. Policy Governance

12.1 Responsibilities

Board of Governors: Ultimate responsibility for anti-bribery compliance and oversight

Vice Rector: Implementation, monitoring, and enforcement of this policy

All Staff: Comply with policy, report concerns, complete training

12.2 Policy Review

This Anti-Bribery Policy is reviewed annually and updated to reflect:

• Changes in anti-bribery legislation
• Lessons learned from incidents or investigations
• Best practices and industry standards
• Organizational changes and new risk areas

13. Contact Information

Policy Owner:
Dr. İbrahim Çıloğlu, Vice Rector
Email: i.chiloglu@brucol.be
Phone: +32 471 09 6641

General Enquiries:
Email: office@brucol.be
Phone: +32 471 09 6641

Anonymous Whistleblowing:
Email: whistleblowing@brucol.be