16.2.5 - BAHÇEŞEHİR UNIVERSITY ANTI-FRAUD, BRIBERY, CORRUPTION, AND ORGANIZED CRIME POLICY

1. Purpose

Bahçeşehir University (BAU) is committed to maintaining the highest standards of integrity, transparency, accountability, and ethical conduct across all its academic, administrative, financial, research, and institutional activities.

This Anti-Fraud, Bribery, Corruption, and Organized Crime Policy establishes the University's institutional framework for preventing, identifying, reporting, investigating, and addressing fraudulent, corrupt, and organized criminal activities.

The University adopts a zero-tolerance approach to fraud, bribery, corruption, and organized criminal activity. Such conduct is incompatible with the University's ethical principles, institutional responsibilities, and commitment to responsible governance.

The objectives of this policy are to safeguard institutional resources, protect the rights and interests of the University community, promote fair and transparent decision-making, prevent the misuse of authority and financial resources, and ensure compliance with applicable national legislation and relevant international standards.

The policy also aims to strengthen institutional awareness, encourage the responsible reporting of suspected misconduct, establish clear expectations for ethical behavior, and ensure that potential violations are addressed through fair and appropriate procedures.

2. Scope

This policy applies to all members of the Bahçeşehir University community, including academic and administrative staff, University management, researchers, students, and individuals undertaking responsibilities on behalf of the University.

It also extends, where applicable, to consultants, representatives, contractors, suppliers, service providers, research collaborators, institutional partners, and other third parties engaged in professional, financial, contractual, or collaborative relationships with BAU.

The policy covers all relevant University activities, including:

• Financial management, accounting, procurement, and contractual arrangements.

• Research projects, grants, externally funded programmes, and the management of research resources.

• Scholarships, financial assistance, donations, sponsorships, and institutional funding.

• Recruitment, appointments, promotions, academic assessments, and administrative decision-making.

• Educational activities, international collaborations, institutional partnerships, and relationships with public and private organizations.

• The use of University property, financial resources, confidential information, and institutional authority.

The policy addresses misconduct occurring within University operations as well as fraudulent, corrupt, or organized criminal activities connected to external relationships that may affect the University's interests, resources, or reputation.

3. Policy Principles and Institutional Commitments

Bahçeşehir University strictly prohibits all forms of fraud, bribery, corruption, and organized criminal activity within or in connection with its institutional operations.

This prohibition applies to all individuals covered by this policy, regardless of their position, seniority, institutional affiliation, or professional responsibilities.

The University does not tolerate the offering, promising, requesting, giving, or accepting of improper benefits intended to influence academic, administrative, financial, contractual, procurement, recruitment, or research-related decisions.

University resources, institutional authority, professional responsibilities, and confidential information must not be used for unauthorized personal gain, improper third-party advantage, or unlawful purposes.

All institutional decisions must be guided by fairness, objectivity, transparency, legitimate institutional interests, and compliance with applicable laws and University regulations.

BAU is committed to preventing misconduct through appropriate institutional safeguards, promoting ethical awareness, encouraging good-faith reporting, protecting individuals against retaliation, and ensuring that allegations are assessed fairly and impartially.

Bahçeşehir University's approach to preventing organized crime, corruption, and bribery is guided by the principles of integrity, transparency, accountability, fairness, impartiality, and zero tolerance for misconduct. The University is committed to upholding these principles across its academic, administrative, financial, and institutional activities, ensuring responsible governance, preventing improper influence, protecting individuals who report concerns in good faith, and addressing suspected violations through fair and appropriate procedures.

4. Definitions

For the purposes of this policy, the following definitions apply:

4.1. Fraud: Any deliberate act, omission, deception, or misrepresentation intended to obtain an improper benefit, cause financial or institutional harm, or unlawfully influence a decision. Examples include embezzlement, misappropriation of funds, falsification of records, fraudulent financial claims, procurement fraud, and unauthorized diversion of research or institutional resources.

4.2. Bribery: The offering, promising, giving, requesting, or accepting of an undue financial or non-financial advantage intended to improperly influence an individual's actions or decisions. Bribery may involve money, gifts, hospitality, services, preferential treatment, employment opportunities, or benefits provided directly or through intermediaries.

4.3. Corruption: The abuse of entrusted authority, institutional position, or decision-making power for improper personal or third-party benefit. Corruption may include favoritism, nepotism, abuse of authority, improper allocation of resources, and conflicts of interest that result in unjustified advantages.

4.4. Organized Crime: Systematic, coordinated, or structured unlawful activities undertaken by individuals or groups to obtain financial or material gain or exert illicit influence over institutional operations. Such activities may include money laundering, collusion, bid-rigging, coordinated fraud, corruption, and other organized illicit conduct affecting the University or its stakeholders.

4.5. Facilitation Payment: An unofficial or unlawful payment or benefit provided to expedite or influence a routine administrative or governmental process.

4.6. Conflict of Interest: A situation in which personal, financial, professional, or other private interests may compromise, or reasonably appear to compromise, an individual's ability to perform institutional responsibilities impartially and objectively.

5. Responsibilities

5.1. University Management

University management is responsible for promoting an institutional culture based on integrity, ethical conduct, transparency, and accountability.

Management is expected to support the implementation of this policy, establish appropriate oversight responsibilities, encourage awareness of misconduct risks, and ensure that relevant concerns are addressed through applicable institutional procedures.

Senior management must demonstrate ethical leadership and ensure that institutional authority and resources are exercised responsibly and in accordance with applicable legislation and University regulations.

The University's Legal Affairs Department is responsible for receiving reports of suspected fraud, bribery, corruption, and organized criminal activity, conducting preliminary legal assessments, and coordinating the referral of reported concerns to the appropriate institutional authorities for further examination or investigation.

5.2. Academic and Administrative Staff

Academic and administrative staff are responsible for complying with this policy and exercising integrity in their professional activities.

They are expected to avoid improper personal benefits, disclose relevant conflicts of interest, use University resources responsibly, and report suspected misconduct in good faith through appropriate institutional channels.

Individuals involved in financial management, procurement, research funding, recruitment, academic assessment, or institutional partnerships have a particular responsibility to maintain impartiality, transparency, and compliance with applicable procedures.

5.3. Students and Researchers

Students and researchers are expected to respect the University's ethical standards and refrain from fraudulent, corrupt, or unlawful conduct in connection with academic, research, financial, or institutional activities.

They are responsible for using institutional resources appropriately and raising concerns when they become aware of suspected misconduct.

5.4. External Representatives and Institutional Partners

Contractors, suppliers, consultants, service providers, research collaborators, and other relevant external parties are expected to comply with applicable legal and contractual obligations and maintain appropriate standards of ethical conduct in their relationships with BAU.

The University expects its external relationships to be free from improper inducements, collusion, fraudulent representations, and attempts to exert undue influence over institutional decisions.

6. Prevention and Risk Management

Bahçeşehir University recognizes that preventing fraud, bribery, corruption, and organized crime requires institutional awareness, responsible decision-making, risk identification, and appropriate safeguards across University operations.

6.1. Training and Awareness

The University promotes awareness of this policy and the ethical responsibilities of individuals engaged in its activities.

Relevant training and awareness initiatives should address the identification of fraudulent or corrupt practices, conflicts of interest, responsible financial conduct, appropriate use of institutional resources, and procedures for reporting suspected misconduct.

Particular attention should be given to activities involving financial transactions, procurement, research funding, contractual relationships, and other areas potentially exposed to elevated risks.

6.2. Risk Assessment and Internal Controls

The University supports periodic assessment of potential fraud, bribery, corruption, and organized crime risks within its academic, administrative, financial, and research-related operations.

Risk assessments should consider the nature, likelihood, and potential consequences of misconduct and inform appropriate preventive measures.

Relevant institutional procedures and internal controls should seek to reduce opportunities for unauthorized transactions, misuse of resources, fraudulent documentation, improper financial practices, and abuse of institutional authority.

6.3. Financial Integrity and Responsible Use of Resources

BAU is committed to promoting transparency, accountability, and responsible financial management.

University funds, research grants, scholarships, donations, sponsorships, and other institutional resources must be used for legitimate and authorized purposes, in accordance with applicable laws, contractual obligations, funding conditions, and University procedures.

Financial and administrative records must accurately reflect relevant transactions and activities.

The University prohibits the falsification of financial documentation, misappropriation of funds, unauthorized expenditure, and diversion of institutional resources for improper personal or third-party benefit.

6.4. Procurement, Contracting, and Institutional Partnerships

Procurement, contracting, and institutional partnership decisions must be guided by fairness, transparency, objective criteria, and legitimate institutional requirements.

The University prohibits collusion, bid-rigging, fraudulent representations, favoritism, and improper influence in procurement and contractual processes.

Appropriate consideration should be given to the integrity and reliability of suppliers, contractors, service providers, and institutional partners.

International partnerships, collaborative research arrangements, and externally funded projects should be conducted in accordance with applicable legal, contractual, and ethical obligations.

6.5. Due Diligence

The University promotes appropriate, risk-based due diligence in relationships with suppliers, contractors, consultants, research collaborators, and other relevant external parties.

Such assessments may consider potential conflicts of interest, legal compliance, the legitimacy of proposed activities, financial or reputational concerns, and indications of fraudulent or corrupt conduct.

The nature and extent of due diligence should be proportionate to the risks associated with the relevant institutional relationship.

6.6. Conflicts of Interest

Individuals involved in University activities are expected to identify and disclose circumstances in which personal, financial, family, or professional interests could compromise the impartial performance of their institutional responsibilities.

Potential conflicts of interest must be addressed in accordance with applicable University procedures.

Appropriate measures may include additional oversight, reassignment of responsibilities, or withdrawal from relevant decision-making processes where necessary to preserve institutional fairness and integrity.

6.7. Gifts, Hospitality, and Improper Benefits

Gifts, hospitality, donations, sponsorships, and other benefits must not be offered, requested, or accepted for the purpose of improperly influencing institutional decisions.

Individuals must avoid situations in which personal benefits could compromise, or reasonably appear to compromise, their professional judgment.

Facilitation payments and other unlawful inducements are prohibited.

6.8. Cooperation with Competent Authorities

Bahçeşehir University is committed to complying with applicable laws concerning fraud, bribery, corruption, money laundering, and organized criminal activity.

Where appropriate and legally required, the University cooperates with competent regulatory, judicial, and law enforcement authorities in matters involving suspected unlawful conduct connected to its institutional activities.

7. Reporting Procedures and Protection

7.1. Reporting Suspected Misconduct

Members of the University community and other relevant stakeholders are encouraged to report suspected fraud, bribery, corruption, or organized criminal activity promptly and in good faith.

Reports are submitted to the University's Legal Affairs Department through designated official and confidential reporting channels. The Legal Affairs Department is responsible for receiving and recording reported concerns, conducting preliminary legal assessments, and coordinating their referral to the appropriate institutional authorities for further examination or investigation.

Where a report involves the Legal Affairs Department, senior University management, or any individual whose involvement could compromise the impartiality of the process, concerns may be submitted directly to an independent authority designated by the University's governing body.

Reports may be submitted confidentially, and anonymous reports are accepted where sufficient information is provided to enable an appropriate assessment.

Individuals reporting suspected misconduct are encouraged to provide relevant facts and supporting information where available but are not required to establish conclusively that a violation has occurred.

All reports are handled impartially and with appropriate confidentiality, in accordance with applicable legislation and University procedures. Where suspected criminal conduct is identified, the Legal Affairs Department coordinates the referral of the matter to competent public authorities, as required by law.

7.2. Confidentiality and Protection Against Retaliation

Bahçeşehir University is committed to providing a secure and confidential environment in which individuals can raise concerns or report suspected misconduct in good faith without fear of retaliation.

The University prohibits retaliation, intimidation, discrimination, or other adverse treatment against individuals who report suspected misconduct or cooperate with related reviews or investigations in good faith.

Reports must be handled with appropriate confidentiality, protecting the identity and legitimate interests of reporting individuals while respecting the rights of all parties involved.

Information relating to allegations should be disclosed only where necessary for legitimate assessment, investigation, or compliance with applicable legal obligations.

Individuals should be able to raise concerns without fear of adverse consequences affecting their employment, academic standing, professional responsibilities, or institutional relationships.

Reporting a concern in good faith does not require an individual to establish conclusively that misconduct has occurred. However, knowingly submitting false or malicious allegations is inconsistent with the ethical standards established by this policy.

8. Investigation, Corrective Measures, and Discipline

Reported allegations of fraud, bribery, corruption, or organized criminal activity must be assessed and, where appropriate, investigated through applicable University procedures.

The Legal Affairs Department provides legal guidance and coordinates with the relevant authorized University bodies throughout the assessment and investigation process, while ensuring that investigative and disciplinary decisions remain within the authority of the competent institutional bodies.

Investigations must be conducted fairly, objectively, impartially, and with due consideration for confidentiality, relevant evidence, applicable legal requirements, and the rights of individuals involved.

Individuals responsible for assessing or investigating allegations must avoid conflicts of interest that could compromise the independence or fairness of the process.

The assessment of allegations should consider the nature and seriousness of the reported conduct, the available evidence, and the applicable institutional and legal framework.

Where misconduct is established, the University may apply appropriate disciplinary, administrative, contractual, or corrective measures in accordance with relevant legislation and University regulations.

Such measures may include disciplinary sanctions, termination of contractual relationships, recovery of misappropriated resources where legally permissible, or referral to competent public authorities.

Disciplinary and corrective measures must be proportionate to the nature and severity of the misconduct.

Where an investigation identifies weaknesses in institutional procedures, financial controls, or risk management practices, the University should consider appropriate improvements to reduce the likelihood of recurrence.

The rights of all individuals involved, including fair treatment and applicable procedural safeguards, must be respected throughout the process.

9. Review and Update

Bahçeşehir University is committed to maintaining the continued relevance and effectiveness of this policy.

The policy will be reviewed and updated periodically to reflect developments in applicable legislation, institutional governance, ethical standards, and relevant national and international frameworks addressing fraud, bribery, corruption, and organized crime.

The review process should consider emerging institutional risks, changes in financial and operational practices, developments in research funding and international partnerships, and relevant findings arising from risk assessments, reported concerns, or institutional reviews.

Where necessary, the policy and its associated procedures should be updated to strengthen prevention, risk management, reporting, investigation, and institutional accountability.

Any revisions must remain consistent with applicable legislation and the University's broader governance responsibilities and institutional regulations.

Date of Initial Adoption: 2021
Reviewed: 2025
Policy Scope: University-wide; applicable to all academic and administrative staff, students, researchers, management, and relevant external stakeholders, including contractors, suppliers, and institutional partners.