16.2.5 - Bahçeşehir University Policy on Organized Crime, Corruption and Bribery: Institutional Principles and Commitments

1. Purpose

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

This policy establishes the University's principles, commitments, and institutional approach to preventing, identifying, reporting, investigating, and addressing organized crime, corruption, bribery, fraud, and related unlawful or unethical practices.

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

The policy aims to safeguard institutional resources, protect the rights and interests of the University community, promote fair and transparent decision-making, prevent the misuse of institutional authority, and ensure compliance with applicable legislation.

It also seeks to strengthen institutional awareness, encourage the responsible reporting of suspected misconduct, protect individuals who raise concerns in good faith, and support fair and appropriate responses to potential violations.

2. Scope

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

Its principles also extend, 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, admissions, 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 within University operations and unlawful or unethical activities connected to external relationships that may affect the University's interests, resources, or reputation.

3. Institutional Principles and Commitments

Bahçeşehir University strictly prohibits organized criminal activity, corruption, bribery, fraud, and the misuse of institutional authority or resources for unlawful personal or organizational gain.

The University's commitments are guided by the following principles:

3.1. Integrity and Ethical Conduct

BAU promotes honesty, fairness, impartiality, and professional integrity in all institutional activities. Academic, administrative, financial, and contractual decisions are guided by ethical standards, legitimate institutional interests, and applicable regulations.

3.2. Transparency and Accountability

The University is committed to transparent and accountable decision-making, particularly in the management of institutional resources, procurement, financial transactions, research funding, partnerships, and administrative processes.

3.3. Compliance with Laws and Regulations

BAU conducts its activities in accordance with applicable national legislation and relevant legal obligations concerning organized crime, corruption, bribery, fraud, money laundering, and related unlawful practices.

3.4. Prevention of Improper Influence and Conflicts of Interest

The University opposes favoritism, nepotism, abuse of authority, and improper influence over institutional decisions.

Individuals involved in University activities are expected to identify and disclose circumstances in which personal, financial, family, professional, or other private interests could compromise their impartiality.

3.5. Responsible Use of Institutional Resources

University funds, assets, facilities, confidential information, and institutional authority are intended for legitimate educational, research, administrative, and societal purposes.

Their misuse for unauthorized personal gain, improper third-party advantage, or unlawful activities is prohibited.

3.6. Fairness and Institutional Accountability

The University is committed to addressing suspected misconduct through fair, objective, and proportionate institutional processes, respecting the rights of all individuals involved and applicable legal requirements.

4. Definitions

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

4.1. 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.

4.2. 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.

4.3. 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.

4.4. 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.

4.5. 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. Prevention of Organized Crime, Corruption and Bribery

5.1. Prevention of Organized Crime

Bahçeşehir University is committed to preventing its institutional activities, resources, facilities, financial arrangements, and partnerships from being used to facilitate or support organized criminal activities.

The University rejects participation in, cooperation with, or institutional support for organized criminal activities, including money laundering, coordinated fraud, illicit trafficking, unlawful financial transactions, and other activities associated with organized criminal networks.

BAU promotes responsible institutional relationships and appropriate consideration of legal, ethical, financial, and reputational risks when establishing or maintaining external partnerships, procurement arrangements, and collaborative activities.

University personnel are expected to exercise appropriate care in their professional responsibilities and avoid actions that could knowingly expose the University to involvement in unlawful activities.

5.2. Prevention of Corruption and Bribery

BAU prohibits the offering, promising, requesting, giving, accepting, or facilitating of improper financial or non-financial advantages intended to influence institutional decisions or obtain preferential treatment.

This prohibition applies to decisions involving admissions, recruitment, academic assessment, research funding, procurement, contracting, financial management, institutional partnerships, and other University activities.

The University rejects practices involving improper influence, abuse of authority, favoritism, fraudulent representations, or the diversion of institutional resources for unauthorized purposes.

Facilitation payments and other unlawful inducements are prohibited.

5.3. Prevention of Fraud

BAU opposes fraudulent conduct in academic, administrative, financial, research, and institutional activities.

The University prohibits falsification of financial or administrative records, misappropriation of funds, fraudulent financial claims, unauthorized expenditure, procurement fraud, and the diversion of institutional resources for improper benefit.

University personnel are expected to maintain accurate records and use institutional resources in accordance with applicable laws, contractual obligations, funding conditions, and University procedures.

6. Prevention and Risk Management

6.1. Training and Awareness

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

Relevant training and awareness initiatives are intended to 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 is 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 organized crime, corruption, bribery, and fraud risks within its academic, administrative, financial, and research-related operations.

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

Relevant institutional procedures and internal controls are intended 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 are 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.

BAU expects suppliers, contractors, service providers, and institutional partners to comply with applicable laws and maintain appropriate standards of ethical conduct.

International partnerships, collaborative research arrangements, and externally funded projects are 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, corrupt, or unlawful conduct.

The nature and extent of due diligence are 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 are 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 are expected to 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 organized crime, corruption, bribery, fraud, and money laundering.

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. Institutional Responsibilities

7.1. University Management

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

Management supports the implementation of this policy, appropriate oversight, awareness of misconduct risks, and the consideration of relevant concerns through applicable institutional procedures.

Senior management is expected to demonstrate ethical leadership and ensure that institutional authority and resources are exercised responsibly.

7.2. 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 particular responsibilities concerning impartiality, transparency, and compliance.

7.3. 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.

7.4. 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.

8. Reporting Procedures and Protection

8.1. Reporting Suspected Misconduct

Members of the University community and relevant external stakeholders are encouraged to report suspected organized crime, corruption, bribery, fraud, or related misconduct promptly and in good faith.

Reports of suspected misconduct are submitted to the University's Legal Affairs Office, which is responsible for conducting an initial legal assessment and referring matters to the relevant University authorities for further examination or action, as appropriate.

All reports are handled in accordance with applicable legislation, University regulations, and institutional procedures, with due regard for confidentiality, impartiality, and the rights of the individuals involved.

Individuals reporting suspected misconduct are encouraged to provide relevant information and supporting documentation, where available, to facilitate an appropriate assessment.

8.2. 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 are 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 is 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.

9. Investigation, Corrective Measures and Discipline

Reported allegations of organized crime, corruption, bribery, fraud, or related misconduct are assessed and, where appropriate, investigated through applicable University procedures.

Investigations are 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 considers 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 considers appropriate improvements to reduce the likelihood of recurrence.

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

10. Monitoring, Review and Continuous Improvement

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

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

The review process considers 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 are updated to strengthen prevention, risk management, reporting, investigation, and institutional accountability.

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

11. Institutional Commitment

Through this policy, Bahçeşehir University affirms its commitment to preventing organized crime, corruption, bribery, and fraud; promoting ethical conduct and responsible governance; and protecting the integrity of its academic, administrative, financial, and institutional activities.

The University regards these commitments as fundamental to maintaining public trust, safeguarding institutional independence, protecting the University community, and contributing to a transparent, accountable, and law-abiding society.

Policy Established: To be confirmed

Scope: University-wide; applicable to all academic and administrative units, University leadership, staff, students, researchers, and relevant external stakeholders.

Implementation: Through applicable institutional governance, administrative, financial, reporting, and oversight procedures.

Monitoring and Evaluation: Through relevant institutional review, risk assessment, and compliance processes.

Last Review: 2025