This Business Partner Code of Conduct has been created to give our business partners a clear view of the values and principles that underpin all our work. Many of the principles in this code focus on compliance with laws and regulations. Such compliance is our minimum standard. In addition, we want to make sure that everything we do and say is consistent with our missions and values that uphold UCAS’ reputation.
We choose our business partners with great care, ensuring that they are the most competent, ethical and reliable. We value our business relationship with them and are committed to making these honest and open. In return, we expect all our business partners to act in accordance with this Business Partner Code of Conduct (Code).
UCAS and its subsidiary, UCAS Media, are committed to operating ethically, demonstrating integrity, and acting responsibly to its customers and wider stakeholders. This Business Partner Code of Conduct (‘Code’) has been created to give our Business Partners a clear view of the values and principles that underpin all our work. Many of the principles in this Code focus on compliance with laws and regulations. Such compliance is our minimum standard. In addition, we want to make sure that everything we do and say is consistent with our missions and values that uphold UCAS’ reputation.
Before contracting with new Business Partners, we onboard Business Partners using a purpose-built third-party risk management system called My Third Party. This system offers us a tailored, step by step, electronic process to onboard new Business Partners and provides consistent assessments across our business, integration with key internal systems to provide a level of automation, and includes automated checks (e.g., FCA register validation / licensed activity / background searching).
As part of our onboarding process, some Business Partners will receive a questionnaire to complete to ensure that we have accurate information directly from you, so our onboarding checks are carried out against the correct contracting entity. This system helps us to readily follow up new Business Partners, understand who you are, the nature of your business, and the scope of the opportunity for us both in an efficient, risk based and transparent way.
In this Code the term “Business Partner” refers to customers, suppliers, agents and any other person or organisation with which UCAS has a business relationship. Where a business partner is an organisation, the term refers to the owners, directors, employees and associates of that organisation.
We choose our Business Partners with great care, ensuring that they are the most competent, ethical, and reliable. We value our business relationship with them and are committed to making these honest and open. In return, we expect all our Business Partners to act in accordance with this Code.
In working with you, we want to always uphold our mission and values, make sure everything we do is ethical and lawful and ensure our business relationships are open, successful, and long term.
We value the confidence and trust of our Business Partners and rely on a mutual relationship where we communicate honestly, openly, and reliably with each other. Any contact between us will be conducted professionally, politely and within appropriate timescales. We always try to ensure that our product information and services and other communications are clear, accurate and honest.
We consider the following principles to be the most important and relevant to our Business Partners and expect them to have the same principles of working.
We are committed to the highest standards of integrity, and we comply with the laws and regulations applicable to the business we are undertaking. We therefore adopt the following ethical practices:
- We do not offer, promise, give, request, agree to receive or accept bribes no matter what the value or business practice may be. This applies to all Business Partners that we work with. We also expect Business Partners acting on behalf of UCAS not to give or receive bribes or to make improper payments.
- We do not make facilitation payments, nor do we allow other people to do so on our behalf.
- We take appropriate action to prevent all forms of fraud.
- We ensure that any gifts or hospitality we give or receive are always clearly for business reasons and are reasonable and appropriate.
- We do not make political donations.
- We do not engage in coercive practices, such as threats or blackmail.
- We expect employees and Business Partners to avoid situations which could lead to a conflict of interest between their own interests and our business interests.
- We expect our Business Partners to report to us all instances of suspected or actual bribery, fraud, or other breaches of our ethical practices in relation to their business activities with us.
We protect our intellectual property (trademarks, design rights, copyrights, proprietary information, and trade secrets) always. We also expect our plans and information to be treated confidentially and not to be disclosed to people outside our organisation unless it is necessary without appropriate authorisation and ensuring that appropriate steps have been taken to protect the data. In return, we respect confidentiality obligations to third parties, including business parties.
We maintain records and ensure that all contracts fairly and accurately reflect our business transactions as they occur. We do not knowingly provide false information. We comply with local data protection laws.
We treat our colleagues with dignity and respect, and promote a safe environment free from discrimination, harassment, and victimisation. We are committed to promoting and maintaining a culture of equality and diversity and comply with relevant legal requirements. We pay fair wages in line with the norms for the industry and market and ensure that our
work environments (including working hours) are healthy and safe and do not put ourselves or others at risk or impact negatively on personal health and safety.
We aim to minimise the environmental impact of our operations through the adoption of sustainable practices and continual improvement in our environmental performance. Our environmental policy can be found here.
We oppose illegal or inhumane labour practices, including the use of forced or child labour. We oppose harsh or inhumane treatment of workers and expect our Business Partners to ensure that there is no slavery or human trafficking in their business or supply chains. Our modern slavery statement can be found here.
UCAS has a zero-tolerance approach to breaches of Financial Services and Markets Act 2000 and associated legislation and regulations (Regulations). The main areas of the Regulations which potentially impact campaign activity undertaken by UCAS are:
- “Regulated activity” and
- Credit brokering or insurance intermediation.
In either case, UCAS is not currently authorised by the FCA where campaigns seek to promote products or services which would amount to “regulated activity” and/or credit brokering or insurance intermediation.
To comply with the Regulations UCAS must take reasonable steps to check all campaigns which include any financial or regulated content and ensure the company running the campaign has the appropriate FCA authorisation. Campaigns which seek to promote or advertise financial products will be checked on a case-by-case basis to ensure UCAS has appropriate contracts in place and any authorisation required to run such a campaign is fully documented. Without these, UCAS will not run such promotions or make such introductions.
To conduct sufficient checks to manage this risk, where a Business Partner’s activities are (or are potentially) caught by the Regulations, UCAS will ask the Business Partner specific questions about the proposed activity and ask for certain assurances/confirmations from the Business Partner’s compliance team. For any campaign which is subject to the Regulations, Business Partners need to be aware that UCAS may request changes to the campaign up until the point where UCAS’ review is complete.
This Code is sent directly to our Business Partners, and we ask that all Business Partners ensure that they have read and understood this Code and will act in accordance with the principles and values it sets out, and we may ask some Business Partners to confirm this to us in writing.
If you become aware of matters in relation to your business activities with UCAS which are inconsistent with this Code, it is very important that you report them to us. You should raise your concerns with our Head of Legal and Governance (firstname.lastname@example.org) and all reports received will be treated in the strictest of confidence.