16.2.5. BAHÇEŞEHİR UNIVERSITY ANTI-FRAUD, BRIBERY, CORRUPTION, AND ORGANIZED CRIME POLICY
1. Purpose:
The Anti-Fraud, Bribery, Corruption, and Organized Crime Policy has been established to ensure transparency, integrity, and adherence to ethical standards in all university activities. The primary objective of this policy is to ensure that all employees, students, and other stakeholders avoid unethical behaviors such as fraud, bribery, corruption, and organized criminal activities; to prevent and detect such acts; and to apply appropriate sanctions where necessary. The policy aims to protect the institution’s reputation, ensure compliance with legal obligations, and enhance reliability in all operations. It also aims to prevent, detect, and address any form of organized or coordinated criminal activity that could harm the university’s operations, finances, or reputation.
2. Scope:
This policy applies to all academic and administrative staff, students, and researchers within the institution. Fraud, bribery, and corruption include fraudulent transactions, misuse of public resources, illegal financial dealings, and unlawful actions conducted for personal gain. The policy is applicable across all university activities, particularly in financial transactions, contracts, procurement, funding, and educational and research projects, with the objective of preventing fraud, bribery, and corruption in these areas.
This policy also covers the prevention, detection, and reporting of organized criminal activities, including any systematic or coordinated attempts to commit fraud, bribery, or corruption within or in connection with the University
3. Policy Statement:
The University prohibits all forms of fraud, bribery, corruption, and organized criminal activity committed by its employees, students, representatives, contractors, and third parties with whom it interacts.
The following terms and their equivalents are defined within this policy:
3.1. Fraud: A deliberate act or omission intended to secure personal gain and/or harm the university. This may include embezzlement, misappropriation of funds, record falsification, and procurement fraud.
3.2. Bribery: Offering, promising, giving, or accepting an undue advantage (financial or otherwise) to influence a decision. This includes facilitation payments intended to expedite routine procedures.
3.3. Corruption: Abuse of entrusted power for personal gain. This may include favoritism, nepotism, or conflicts of interest that result in financial or other benefits.
3.4. Organized Crime: Systematic, coordinated, and unlawful activities undertaken by individuals or groups to obtain financial or material gain, including but not limited to money laundering, collusion, bid-rigging, and illicit influence over institutional operations.
4. Definitions:
This policy uses the following definitions.
4.1. Facilitation Payment: An unofficial or illegal payment or gift given to expedite a routine or authorized government process.
4.2. Conflict of Interest: A situation in which an individual’s professional responsibilities may be compromised by personal interests.
4.3. Organized Criminal Activity: Any collective, coordinated, or structured effort by multiple individuals or entities to engage in fraudulent, corrupt, or illicit actions that may affect the university or its stakeholders.
5. Responsibilities:
The responsibilities of parties under this policy are summarized as follows:
5.1. University Management: Responsible for implementing and maintaining an effective program, including training and risk assessments. The University is committed to full compliance with all laws related to fraud, bribery, corruption, and organized crime prevention.
5.2. Employees and Students: Responsible for complying with this policy, reporting suspected incidents of fraud, bribery, corruption, or organized crime, and completing required training.
5.3. Representatives and Contractors: Subject to contractual obligations that reflect the University’s commitment to preventing fraud, bribery, corruption, and organized criminal activity.
6. Prevention:
Bahçeşehir University takes proactive steps to prevent fraud, bribery, corruption, and organized crime.
6.1. Training: Regular training for employees, students, and relevant parties on this policy and related risks.
6.2. Risk Assessments: Periodic evaluations to identify and mitigate vulnerabilities related to fraud, bribery, corruption, and organized crime.
6.3. Due Diligence: Robust due diligence procedures in the selection of suppliers, partners, subcontractors, and research collaborators.
6.4. Gifts and Hospitality: Clear guidelines on the acceptance and offering of gifts and hospitality.
6.5. Conflict of Interest Management: Mandatory disclosure of potential conflicts of interest by employees and senior personnel, with management procedures in place.
6.6. Whistleblower Protection: Providing a secure and confidential environment for reporting concerns without fear of retaliation.
6.7. Collaboration with Authorities: The University cooperates fully with national and international law enforcement and regulatory bodies to prevent and address organized criminal activities that may intersect with academic or administrative operations.
7. Reporting Procedures:
Anyone who suspects fraud, bribery, corruption, or organized criminal activity is encouraged to report it promptly through the following channels.
7.1. Dedicated Reporting Line: A confidential phone line or online reporting platform for related concerns.
7.2. Supervisor: The direct supervisor of the individual under suspicion.
7.3. Compliance Officer: The designated University official responsible for overseeing the anti-fraud, bribery, corruption, and organized crime prevention program.
8. Investigation and Discipline:
All reported allegations will be investigated promptly, impartially, and confidentially. Individuals found to be involved in fraud, bribery, corruption, or organized crime will face disciplinary actions, including possible dismissal. Bahçeşehir University may also report criminal actions to the appropriate authorities.
9. Review and Update:
This policy will be reviewed and updated regularly to reflect legislative changes, best practices, and the University’s operational environment. Revisions will also consider new national or international frameworks related to organized crime prevention, ensuring continued compliance and institutional resilience.
Created: 2021
Updated: 2024
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