Anti-Bribery and Anti-Corruption Policy

Policy adopted in: 2018

Policy updated in: 2023

Application: Applicable to all the stakeholders

Purpose:

Galgotias University is committed to upholding the highest ethical standards and fostering a corruption-free environment, as mandated by the Indian Penal Code (IPC) and the Prevention of Corruption Act (PCA), 2018. This policy outlines our zero-tolerance approach to bribery and corruption.

Definitions

• Bribery:As defined by the IPC (Section 171 & 172), offering, promising, giving, or soliciting anything of value to influence the actions of another person in a dishonest or illegal way. This can be done directly or indirectly, and the value can be monetary or non-monetary (e.g., gifts, hospitality, favors).
• Corruption:The abuse of entrusted power or position for personal gain or to benefit others unlawfully. This can include various acts like favoritism, nepotism, embezzlement, and extortion.
• Undue Advantage:Any benefit, service, or treatment that gives an unfair or improper advantage to a person or entity in a university process.

Policy

This policy strictly prohibits the following:

• Offering or Accepting Bribes:This includes any attempt to influence decisions related to:
  • Admissions (e.g., offering money or gifts to secure admission)
  • Grades (e.g., offering bribes to improve grades)
  • Research funding (e.g., offering kickbacks in exchange for research grants)
  • Contracts and procurement (e.g., bribing officials to secure contracts or purchase orders)
  • Employment (e.g., offering bribes to get a job)
  • Any other university activity that can be influenced improperly.
• Facilitation Payments:Offering small bribes to expedite routine or lawful actions (e.g., greasing palms to get a document processed faster) is strictly prohibited.
• Misuse of Resources:The misuse of university resources (e.g., equipment, funds, facilities) for personal gain or to benefit others inappropriately is forbidden.
• Conflicts of Interest:Engaging in any activity that creates a conflict between personal interests and professional duties at the university. This includes situations where a staff member or faculty member has a financial or other stake in a company or organization that does business with the university.
• Collusion:Participating in schemes or arrangements to deceive or mislead the university for personal gain or to benefit others unlawfully.

Gifts and Hospitality

• Accepting or offering gifts, hospitality, or entertainment must be reasonable and not create a perception of a bribe. Examples of reasonable gifts could include small tokens of appreciation or invitations to university events.
• The University established specific guidelines or require prior approval for accepting or offering gifts or hospitality exceeding a certain value (e.g., Rs. 5,000) or involving specific categories of individuals (e.g., government officials, admissions committee members).

Sponsorships

Sponsorships are closely allied to the various types of community / academic activities undertaken by the university. These range from sponsoring educational scholarships to local sports teams. Any sponsorship must be for genuine business or charitable objectives without any element of quid pro Quo. Any such sponsorship must be transparent, duly approved from the competent authority, properly documented in the record.

Reporting Procedures

The University encourages everyone to report suspected acts of bribery or corruption. Reporting can be done confidentially through designated channels:

• A dedicated email address
• A University ombudsman or ethics committee.

The University will:

• Investigate all reported allegations promptly, thoroughly, and confidentially (to the extent permitted by law).
• Uphold the anonymity of the whistleblower to the best of its ability.
• Protect those who report concerns in good faith from retaliation.
• Provide feedback to the whistleblower on the outcome of the investigation (where possible).

Compliance and Training

The University:

• Provides regular training programs to educate everyone about this policy, the IPC, and the PCA, 2018.
• Integrate discussions on anti-bribery and anti-corruption into relevant courses and curricula, particularly for students pursuing management or public administration degrees.

Consequences of Violations

Violating this policy will be considered a serious offense and results in disciplinary action, up to and including:

• Students:Suspension, expulsion, or cancellation of degrees.
• Faculty, Staff & Administration:Termination of employment, disciplinary action, or legal proceedings.
• Third-Party Representatives:Termination of contracts, blacklisting from future university projects, and potential legal action.

Approving authority

The Vice-Chancellor shall be the approving authority for implementing actions related to bribery and corruption at the campus.