1. Policy Statement
European University of Lefke is committed to operating its activities with the highest ethical standards and good governance. The university has “zero tolerance” against” bribery or corruption and it expects staff and representatives to reflect this commitment in their work, treating in an honest manner with personal integrity.
Bribery or corruption of any kind by University staff will be treated as an important disciplinary offence. University staff must not offer, promise or pay bribes and should not request or receive bribes. In case of this event, the University will be taking decisive actionand University staff will be treated as a serious disciplinary action, that could include dismissal and legal action.
2. Scope and Purpose
This policy applies to all University staff, including temporary or agency staff, voluntary workers and unpaid staff members and staff of subsidiary companies. The policy applies to all activities of the University that is related to its research, teaching, commercial or other activities, and exists for the protection of members of staff and the University. The University will be expecting any individual or organisation performing services for or on its behalf, to adhere to this policy or otherwise have equivalents procedures in place to prevent bribery and corruption. These include agents and others who represent the University and suppliers, consultants and private sector partners who perform services for the University or on its behalf, wherever located in the world.
3. Principles
The University and staff members are obliged to comply with the following principles:
• Bribes must not be offered, committed, promised, requested, agreed to or accepted.
• In conformity with the University values and constitution, the University does not make political donations regardless to individual, political parties or other political organisations whether national or international) and any donations made on behalf of the university by any member of staff will be assumed a breach of this policy.
• Disciplinary action will be taken by the University or its subsidiary companies against staff who violate this policy. This covers the sanction of summary dismissal in the case of paying or receiving bribe by the staff. Similar action would be taken against other involved parties providing services for the University who fail to obey this policy or equivalent anti-corruption standards, which includes termination of University’s connection with them.
• The University encourages all staff to report any concerns related with corruption at immediate effect and will endorse staff that do so. All reporting will be handled with delicacy and the University is pledged to make sure that none of the staff members who reports a corruption concern in good faith suffers any damage for doing so.
• A deliberate failure to report suspicions of corruption or bribery by others will also be subject to disciplinary action.
• Third parties who have or are suspected to offering or accepting bribes should not be engaged to any work for the University.
4. Responsibilities
All staff members must read and devote strictly to this policy. The University Court has ultimate responsibility for approval of this policy; monitoring and receiving updates on the implementation of this policy.
Chief Operating Office is responsible for:
• To communicate the policy to staff members
• To ensure the policy is reviewed at least once in every 3 years, considering account of any relevant regulations and legislations that includes changing circumstances.
• To conduct, at least once in every 2 years, an evaluation of the bribery and corruption related risks faced by the University.
• To ensure an audit, at least once in every 5 years, of the enforcement of this policy.
Heads of School / Director of Institute / Heads of Department / Director of College are responsible for:
• To ensure that staff in their area of responsibility are aware of this policy
• To report any suspicion of bribery or corruption; either to the responsible line-manager and/or through the University’s policy.
All staff members are expected to;
• To adhere the University’s anti-bribery and corruption policy.
• To undertake the University’s training
• To report any suspicion of bribery or corruption to their manager.
5. Breaches of this Policy
In the case of an allegation is made to the effect that a staff member has breached this policy, the matter will be handled under the University’s Disciplinary Policy. Where, after an investigation and succeeding disciplinary hearing, allegations are upheld, the employee may be subject to formal action which could eventually include dismissal. Where third parties performing services or on behalf of the University are in breach of this policy, action may be taken to bring to an end the relevant contractual relationship. For clarity, breaches of this policy include:
• Paying bribes
• Receiving bribes
• Failure of a commercial organisation to prevent bribery
6. Trainings
The University has developed training program to assist staff members in understanding their responsibilities and duties in terms of Anti-Bribery and Corruption Act. This training should be completed by all staff, including agents employed by the University, where their duties may place them in a situation where they might be exposed to bribery or corruption.
The objectives of the training are that participants will be able to:
▪ Understand what bribery is (direct and indirect forms of Bribery).
▪ Identify instances of corruption and feel confident about reporting them.
▪ Anticipate difficult situations and take the necessary steps to avoid them.
▪ Deal with ethical contradictions in the workplace.
▪ Understand that the onus is on the individual to comply with the Act.
▪ Apply the knowledge acquired in the course to comply with the Act.
▪ Inculcate respect for the law and inspire an ethical approach amongst all colleagues.
▪ Demonstrate clear understanding of the Act after the training.