Sorrento Education

1. Purpose and Commitment

At Sorrento Education, we are committed to providing honest, transparent, and ethical admissions consultancy services to families seeking placements in UK and US education systems. This policy sets out our zero-tolerance approach to bribery and corruption, ensuring all advice and business decisions are made fairly, professionally, and strictly in the best interests of our clients.

2. Scope and Application

This policy applies to all employees, consultants, contractors, agents, and any third parties acting on behalf of Sorrento Education, whether operating in the UK, East Asia, or elsewhere. All representatives must comply fully with all applicable anti-bribery and anti-corruption laws, including The UK Bribery Act 2010.

3. Policy Statement: Zero Tolerance

We strictly prohibit offering, giving, soliciting, or accepting any form of bribe, kickback, or improper inducement related to admissions applications, educational institutions, or any business activity.

Specifically, we will not tolerate corrupt practices intended to influence admissions outcomes or secure unfair advantages, nor will Sorrento Education accept any form of commission or monetary incentive from educational institutions in exchange for student placement or referral.

4. Gifts, Hospitality, and Payments

Modest gifts or hospitality may occasionally be exchanged as part of customary business etiquette, but must never be offered or accepted with the intention of improperly influencing professional decisions or obtaining preferential treatment.

• Any gifts or hospitality given or received must be reasonable, proportionate, transparent, and recorded in line with company procedures.

• We strictly prohibit the making of "facilitation payments" (small, typically illegal payments made to secure or accelerate routine government actions, such as visa processing).

5. Responsibilities and Reporting Concerns

• All staff and representatives must comply fully with this policy and report any suspicions of bribery or corrupt conduct without delay.

• Senior management will ensure that adequate training and guidance are provided to prevent unethical behaviour.

• We encourage all employees, clients, and partners to report any concerns or suspicions regarding bribery or unethical practices confidentially and without fear of reprisal (whistleblower protection).

• Reports should be made immediately to [Designated Contact Person or Department], who will handle them promptly and with discretion.

6. Consequences and Review

Breaching this policy will result in severe disciplinary action, including dismissal or termination of contract, and could lead to criminal prosecution under The UK Bribery Act 2010 and other relevant international anti-bribery laws.

This policy will be reviewed annually and updated as necessary to ensure ongoing compliance with legal requirements and best practice standards.