Anti-bribery policy
Scholarships move money, and money attracts people who sell influence. Our answer is simple: at PolyGrants, nobody buys an outcome and nobody sells one, in any country, in any currency, for any amount. This policy says what that means in practice, for the people who work for us, for the institutions we work with, and for you.
Zero tolerance, from the top
PolyGrants Ltd prohibits bribery and corruption in every form, everywhere it operates, with no exception and no minimum amount. This rule is adopted and owned by the directors of the company and binds everyone who acts for PolyGrants; no target, deadline or instruction from anyone, however senior, can ever justify breaking it.
We would rather lose an application, a partnership or an entire market than win anything with a bribe. A service whose promise is that results cannot be bought must begin by refusing to buy them.
Who this policy binds
This policy binds every director, employee and adviser of PolyGrants, and every partner office, representative, contractor and supplier acting for PolyGrants or on its behalf, in every country and at every stage of the Service. It covers their dealings with applicants and their families, with institutions and authorities, with suppliers, and with each other.
It also speaks to you as an applicant. It tells you what nobody may ever ask of you, and what you must never offer; the applicant side of these rules is already part of your agreement with us through the Terms of Service.
This policy completes the general PolyGrants documents, which continue to apply. If it ever conflicts with one of them on a point, the general document prevails on that point, led by the Terms of Service.
What a bribe is
A bribe is anything of value offered, promised, given, requested or accepted, directly or through someone else, to influence a decision improperly or to reward one already influenced. The label does not matter: a payment called a gift, a commission, a donation, an expediting fee or a consulting fee is still a bribe when its real purpose is influence.
Anything of value includes, among other things:
- cash in any form: notes, transfers, mobile money, vouchers or credit;
- gifts, hospitality, travel or entertainment beyond the modest courtesies this policy allows;
- jobs, internships, contracts or admission places granted as favours;
- inflated, false or split invoices, or commissions with no genuine service behind them;
- charitable or political donations made to win a decision;
- confidential information, or any other favour with real value to the person receiving it.
For applicants and families: outcomes are not for sale
Applying through PolyGrants is free, and every amount PolyGrants can ever charge you is on the Payment information page: the single fee, due only if you decide to accept an offer, and any optional service you choose to order, quoted in advance. Both are paid only through the official channels shown in your account.
Nobody can sell you a better result. Matching, submission, results and their timing cannot be improved by any payment to any person. Anyone who offers you a guaranteed admission, a faster answer or a bigger scholarship in exchange for money is defrauding you, whoever they claim to be: refuse, keep the evidence, and report it through the Contact page.
The rule runs in both directions. Do not offer money, gifts or favours to PolyGrants staff, advisers or partner offices, before, during or after your application. They must refuse and report it, and the offer itself is prohibited conduct under the Terms of Service that can put your application at risk.
Gratitude needs no money. When a result makes you proud, a thank-you message, an honest review or your story shared with other students is exactly the reward our team hopes for. Our people may not accept money or gifts from applicants or their families, whatever the amount and whatever the occasion.
Public officials, visas and institutions
PolyGrants never pays, offers or promises anything to a public official, a visa officer, an embassy employee or a member of an institution's staff to influence a decision, to obtain confidential information or to gain any other improper advantage. Admission decisions belong to institutions and visa decisions to the authorities, as the Disclaimer explains, and your file stands before both on its merits alone.
The only amounts ever paid to authorities and institutions are the official charges they set and publish themselves: visa fees, tuition, tests and the other third-party costs listed on the Payment information page. They are paid to the authority or institution itself, at its official rate, against its official receipt.
Because the law is at its strictest around public officials, any dealing with an official that would go beyond published procedures and published charges needs the prior written approval of a director of PolyGrants; in practice, the answer is no.
Facilitation payments and speed money
A facilitation payment is a small unofficial payment made to hurry a routine step: a stamp, a signature, a place in a queue. In some places it is treated as normal. It is still a bribe, and PolyGrants prohibits it absolutely, whatever the amount, however common the practice, in every country where we work.
A demand for an unofficial payment is refused politely, recorded, and reported to PolyGrants, and where appropriate to the authority the person belongs to. An application that moves slowly and honestly beats one that moves quickly and corruptly, every time.
One exception exists: if a payment is demanded under a real threat to someone's safety or freedom, safety comes first. The person pays what the situation forces, then reports it to PolyGrants as soon as it is safe. Such a payment is recorded honestly for what it was; it is never budgeted, repeated or treated as a way of working.
Gifts and hospitality
From applicants and their families: nothing. PolyGrants staff, advisers and partner offices may not accept money, gifts, meals or favours from applicants or their families, of any value, at any time. A result never owes anyone a present, and a present never buys anyone a result.
Between professionals, ordinary courtesy is allowed within strict limits; when in doubt, decline or ask first. A gift or an invitation connected to PolyGrants' work is acceptable only when all of the following are true:
- it is modest and occasional, and it is never cash or anything that works like cash, such as a voucher or a transfer;
- it is given and received openly, and declared to PolyGrants management, which keeps a record of it;
- it is not requested, and nothing is pending: no decision that concerns the giver is waiting to be made;
- it would look harmless described on the front page of a newspaper.
Partner offices, representatives and suppliers
PolyGrants cannot do through others what it may not do itself. Partner offices, the authorized local agents described on the Payment information page, and every representative, contractor and supplier who acts for PolyGrants, are chosen with care: we look at who they are and how they work before engaging them, their agreements bind them to this policy in writing, and what we pay them is documented, proportionate to real services, and traceable.
A representative who demands, offers or accepts a bribe, or who collects any amount outside the official channels and official receipts, loses the engagement immediately, however valuable the relationship, and is reported to the authorities where the law requires it.
Recruitment follows the same rule from the first click: applying for a role at PolyGrants is free at every stage, as the Recruitment policy states, and nobody may charge a candidate anything.
Political and charitable contributions
PolyGrants makes no political donations of any kind, to any party, candidate or campaign, in any country.
Charitable giving and sponsorship are possible, and are governed by one test: they must be transparent, documented, made to genuine organisations, and connected to no decision anyone is waiting on. A donation is never a route to influence, and never a favour to a person in a position to affect PolyGrants' business.
Honest books and records
Every payment PolyGrants makes or receives is recorded accurately, at its real amount, with its real purpose, in accounts that show it. No off-the-books account, no misdescribed invoice and no undocumented cash exists in our operation. A payment that cannot be recorded honestly is a payment we do not make.
You can see this rule at work in your own account: every fee is shown with its amount and its reason before you decide, and every payment produces a receipt that stays available to you. Keep your receipts; they protect you, and they keep everyone honest.
Speak up: reporting without fear
If anyone asks you for an irregular payment, offers you one, or pressures you to ignore one, tell us: through the Contact page, by email to , or, if you are an applicant, simply to your adviser or to . Say what happened, who was involved and when; evidence helps, but a report without evidence is still welcome. You may report anonymously, and an anonymous report is read and acted on like any other.
Every report is taken seriously, looked at promptly, and handled as confidentially as a proper investigation allows.
Nobody suffers for speaking up in good faith. A report never harms your application, your employment or your engagement with PolyGrants, even if it turns out to be mistaken. Retaliation against a reporter is itself a breach of this policy, treated as seriously as the conduct reported.
What happens when this policy is broken
For staff and advisers, breaking this policy means disciplinary action up to and including dismissal. For partner offices, representatives, contractors and suppliers, it means immediate termination of the engagement. For an applicant who offers or pays a bribe, it means the consequences set out in the Terms of Service, which can go as far as rejection of the application, the voiding of offers obtained and closure of the account.
Bribery is also a crime. Where the law requires it, or where the seriousness of the conduct justifies it, PolyGrants informs the institutions affected and the competent authorities, and cooperates with any investigation that follows.
The law behind this policy
PolyGrants Ltd is incorporated in England and Wales, so this policy is written to meet the United Kingdom Bribery Act 2010, one of the strictest anti-corruption laws in the world, and a law that follows a British company wherever it acts. The anti-corruption laws of every country where we operate apply alongside it. Where two rules differ, we follow the stricter one.
This policy is a public statement of how PolyGrants works, published so that anyone can hold us to it. Your agreement with PolyGrants remains the Terms of Service and the documents incorporated there.
Ownership, training and review
This policy is owned by the directors of PolyGrants Ltd. Everyone who works for PolyGrants receives it at the start of their engagement and agrees in writing to follow it, and representatives and partner offices accept it as part of their agreements.
It is reviewed at least once a year, and sooner whenever the law, the business or an incident shows it needs to change. The date at the top of this page states when it was last updated; earlier versions are available on request.
Contact
Reports and questions about this policy: or the Contact page. Formal notices: PolyGrants Ltd, 128 City Road, London, EC1V 2NX, United Kingdom.