Anti-Corruption and Anti-Bribery Policy

Policy Number	MU-POL-011	Version	1.0
Issue Date	January 2025	Review Date	January 2027
Policy Owner	Quality Assurance and Internal Audit Department	Scope	All Employees and Students

I. Purpose and Objectives

Midocean University reaffirms its commitment to the highest standards of integrity, transparency, and accountability in all its dealings.

This policy prohibits all forms of corruption and bribery and establishes procedures for reporting, investigation, and handling cases, while protecting the University’s resources and reputation through strict oversight and preventing any financial or administrative manipulation.

II. Scope

All University personnel, including faculty members, administrative staff, and contractors.
Members of the Board of Directors and governing committees.
Partners, suppliers, and external consultants.
Any party acting on behalf of or in the name of the University.

III. Definitions

Corruption: The misuse of authority, resources, or position to obtain personal gain or benefit a third party.
Bribery: Offering, accepting, requesting, or promising any material or non-material benefit to induce improper conduct.
Conflict of Interest: A situation in which an employee’s personal interests conflict with their professional obligations toward the University.

IV. Core Policy Provisions

1. Prohibition of Bribery and Corruption

Offering or accepting bribes in any form or under any circumstances to or from any party is strictly prohibited.
Misappropriation of University funds or resources, or their unlawful diversion, is prohibited.
Manipulation of academic, financial, or administrative records is prohibited.

2. Gifts Policy

Gifts exceeding the value limit specified in the detailed regulations shall not be accepted unless prior written approval is obtained.
All gifts exceeding the specified minimum limit shall be recorded in the approved Gift Register.
Accepting gifts that may influence institutional decisions is prohibited.

3. Conflict of Interest Management

Employees shall immediately disclose any actual or potential conflict of interest to their direct supervisors.
Employees shall not participate in decisions that directly affect their personal interests or the interests of their relatives.

4. Financial Transparency

Strict financial procedures shall be applied, requiring multi-level approval for significant expenditures.
Independent financial audits shall be conducted periodically.
Accurate, complete, and auditable financial records shall be maintained at all times.

V. Reporting Channels

The University shall provide secure and encrypted electronic channels for reporting violations, with the option of anonymous reporting.
Full protection shall be provided to individuals who report in good faith against any form of retaliation or accountability.
All reports shall undergo thorough investigation in accordance with approved procedures.

VI. Disciplinary Actions and Training

Disciplinary actions shall range from a formal warning to immediate dismissal and referral to competent legal authorities when required.
All employees shall complete anti-corruption training upon appointment and periodically thereafter.

VII. Review and Updates

This policy shall be reviewed annually in light of legislative developments and the requirements of international accreditation bodies.