This policy is titled “Anti-Bribery and Corruption Policy” of the University.

Introduction

This policy sets forth the ICFAI Foundation for Higher Education’s (IFHE), a deemed-to-be University, commitment to maintaining the highest ethical conduct and integrity standards in all its activities. The University has established the Anti-bribery and Corruption free Policy as part of this commitment.

Scope of the Policy

This policy applies to all Students, employees, vendors, contractors, consultants, agents, and any other individuals or entities associated with IFHE.

Definitions

1. Bribery is offering, giving, receiving, or soliciting of anything of value to influence the actions of an individual in a position of trust or authority.
2. Corruption is the abuse of entrusted power for private gain.
3. Departmental corruption is any form of corruption or unethical behavior within specific departments or units of the University.

Commitment to Compliance

IFHE prohibits bribery and corruption in any form, whether involving public officials or private individuals. IFHE is committed to complying with all applicable laws and regulations related to anti-bribery and corruption as per the law of the land.

Internal Reporting System

IFHE has established an internal reporting system to allow employees and stakeholders to report suspected instances of bribery or corruption confidentially and without fear of retaliation. Reports can be made through designated channels like an anonymous letters or email address.

Committee for Anti-Bribery and Corruption

A dedicated committee, comprising representatives from various departments, has been established to oversee the implementation and enforcement of this policy. The committee is responsible for:

1. Reviewing reported incidents of bribery and corruption.
2. Conducting investigations as necessary.
3. Implementing corrective actions and sanctions as appropriate.
4. Providing regular updates to senior leadership and the Board of Management.

Audit System

Regular audits will be conducted to assess compliance with this policy and identify any areas of vulnerability to bribery or corruption. The audit system will:

1. Review financial transactions and records for irregularities.
2. Assess the effectiveness of internal controls and procedures.
3. Recommend improvements to mitigate bribery and corruption risks.

Vigilance System

A vigilance system will be established to identify and address potential bribery or corruption proactively. This system will involve:

1. Conducting risk assessments to identify areas of vulnerability.
2. Providing employee training and awareness programs on anti-bribery and corruption policies and procedures.
3. Monitoring external developments and regulatory changes related to bribery and corruption.

Addressing Corruption in Key Departments: Remedial Actions

Each department will identify specific types of corruption that may occur within its operations and develop appropriate steps to address them. In particular, IFHE will focus vigilance and internal audit efforts on the following key departments, which are often susceptible to bribery and corruption:

1. Procurement and Purchasing:
• Corruption Types: Collusion with vendors and suppliers, bid rigging, kickbacks.
• Steps to address: Implement strict procurement policies and procedures, conduct thorough due diligence on vendors, and rotate procurement staff responsibilities regularly to prevent conflicts of interest.
2. Finance and Accounting:
• Corruption Types: Misappropriation of funds, fraudulent financial reporting.
• Steps to Address: Segregate duties within the finance department, implement regular reconciliation and review processes, and conduct surprise audits of financial records.
3. Human Resources:
• Corruption Types: Nepotism, favoritism in hiring and promotion decisions.
• Steps to Address: Establish clear hiring and promotion criteria, implement transparent recruitment processes, and provide training on ethical decision-making for HR staff.
4. Research and Grants Management:
• Corruption Types: Misuse of research funds, plagiarism, falsification of data.
• Steps to Address: Implement robust grant management systems, conduct regular audits of research projects, and promote a culture of academic integrity and ethical conduct.
5. Facilities and Maintenance:
• Corruption Types: Acceptance of bribes from contractors, misallocation of resources.
• Steps to Address: Implement strict controls over contractor selection and payment processes, conduct regular inspections of facilities and maintenance work, and encourage reporting of any suspicious activities.

By focusing vigilance and daily internal audit efforts on these key departments, IFHE aims to proactively identify and address potential instances of bribery and corruption, thereby upholding the highest standards of integrity and accountability.

Measures against Briberies and Corrections

In the event that bribery or corruption is detected, the University will take immediate action to address the issue. Depending on the severity and gravity of the violation, actions may include:

1. Disciplinary action, up to and including termination of employment.
2. Referral to law enforcement authorities for criminal prosecution.
3. Implementation of corrective measures to prevent future occurrences.

Training and Awareness

All employees and relevant stakeholders will receive training on this policy and their responsibilities in preventing bribery and corruption. Training programs will be tailored to address specific risks and scenarios relevant to each department or role.

Compliance Monitoring

IFHE will regularly monitor compliance with this policy and assess its effectiveness in preventing bribery and corruption. Any updates or revisions to the policy will be communicated to all Students, employees and stakeholders.

Review and Revision

This policy will be reviewed periodically to ensure its effectiveness and relevance, with revisions made as necessary in consultation with relevant stakeholders. Updates will be communicated transparently.

Conclusion

IFHE is committed to fostering a culture of integrity, transparency, and accountability. The University believes that by adhering to the principles outlined in this policy and working together, it can effectively combat bribery and corruption in all its forms and maintain high levels of integrity.