Anti-bribery policy

1. About this policy

Last updated: 10 October 2026.

This policy applies to everyone who works for or on behalf of Oxford City Academy for Education and Development (OAED) and Oxonia Academy, including staff, contractors, agents, resellers and partners. It is designed to meet the UK Bribery Act 2010 and the anti-corruption laws of the countries where we work, including Nigeria, Ghana, Kenya, South Africa, the Gulf states, Malaysia, Turkey and EU member states. Where local law is stricter, local law applies.

2. Our position

We have zero tolerance of bribery and corruption. We would rather lose a contract than win it improperly. Many of our customers are public universities and ministries, so we hold ourselves to a high standard when dealing with public officials.

3. What is not allowed

• Offering, promising or giving anything of value to influence a decision improperly.
• Asking for or accepting anything of value in return for an improper decision.
• Facilitation payments, meaning small unofficial payments to speed up routine actions such as permits or customs clearance.
• Using an agent, partner or family member to do any of the above.
• Hiding payments or recording them falsely.

4. Gifts and hospitality

Modest gifts and hospitality can be part of normal business, such as a working lunch at a demo. They must be reasonable, open, never in cash, and never offered to people involved in a live tender. Anything beyond a modest value must be approved in advance by a director and recorded in our gifts and hospitality register.

5. Public officials and tenders

Extra care applies when dealing with public universities, ministries, regulators and their staff. We follow tender rules strictly and do not give gifts or hospitality to officials involved in a procurement. Our prices are published openly on our pricing page and on the Nigeria pricing and Education discounts pages, and any discount is recorded in the order form.

6. Agents and partners

Before we work with an agent, reseller or partner, we check their background and reputation, agree written terms that include anti-bribery commitments, and pay them only for real work, through traceable payments to accounts in their own name. See Partners.

7. Reporting concerns

Anyone who suspects bribery connected to our business should report it at once to legal@oxonia.ai. You can ask for your report to be treated confidentially. We will not penalise anyone for raising a genuine concern in good faith, even if it turns out to be mistaken. Breaches of this policy may lead to disciplinary action, ending a contract and reporting to the authorities.

8. Ownership and review

This policy is owned by the board of Oxford City Academy for Education and Development (OAED) and reviewed at least once a year.