Anti-Fraud, Bribery, Corruption & Organized Crime Policy

Coordination Office of Corporate Planning and Data Management

1. Policy Statement

Atılım University is committed to undertaking its academic and administrative activities with integrity, transparency, adherence to ethical principles, accountability, and full compliance with the law. The University adopts a zero-tolerance policy against all activities that constitute fraud, bribery, corruption, embezzlement, irregularities, conflicts of interest, and organized crime. This policy establishes the minimum ethical and legal standards to which everyone within the University and all third parties operating on behalf of or in connection with the University are obliged to adhere.

2. Purpose

The purpose of this policy is to prevent, detect, deter, and sanction fraud, bribery, corruption, and organized crime activities that may arise in the financial, administrative, and academic processes of the University.  The policy aims to protect the reputation, assets, resources, and decision-making processes of the University, foster a culture of ethical behavior, create a fair and trustworthy environment in education, and strengthen compliance with national legislation and international ethical standards.

3. Scope

This policy is binding on our academic and administrative staff, students, scholarship holders, interns, volunteers, temporary staff, contract employees, consultants, suppliers, contractors, subcontractors, business partners, and third-party representatives. The policy covers the areas of activity of the University, as well as our academic and administrative units and their processes, budget and financial transactions, purchasing, research projects, scholarship and fund management, recruitment, contracts, external relations, partnerships, and other university-wide processes.

4. Definitions

Bribery: Any material or intangible benefit, advantage, service, or convenience provided or offered in exchange for the misconduct of an individual or organization.

Fraud: Intentional misrepresentation, forgery, embezzlement, fraudulent document production, false reporting, or similar behavior intended to gain an unfair advantage or to cause harm.

Corruption: Abuse of authority, position, or resources for personal gain; conflict of interest; abuse of power; creating unfair influence.

Organized Crime: Illegal activities undertaken in a planned, continuous, and systematic manner by more than one individual or group; money laundering; coordinated fraudulent schemes.

Conflict of Interest: Instances where an individual's personal interests pose a risk of conflicting with the interests of the University; such situations must be disclosed.

5. Basic Principles

  1. Zero tolerance: Bribery, corruption, fraud, embezzlement, organized crime, and all similar illegal and unethical behaviors are strictly prohibited.
  2. Legal and ethical compliance: All activities are conducted in accordance with applicable legislation, the code of ethics of the University, and international standards.
  3. Transparency: All decision-making, spending, appointment, selection, and evaluation processes within the University are open, traceable, and recorded.
  4. Accountability: Every individual is responsible for the accuracy of the actions and decisions within their jurisdiction.
  5. Equality and impartiality: No individual or institution is privileged; processes are conducted fairly.
  6. Confidentiality: The reporting, investigation, and evaluation of suspicious activities are conducted confidentially.
  7. Non-Retaliation: No person who makes a good-faith report will be subject to discrimination, threats, coercion, punishment, or retaliation.
  8. Education and Awareness: The university community is regularly informed about ethical and anti-corruption practices.

6. Investigation and Evaluation

  • All complaints and reports are reviewed promptly, impartially, confidentially, and fairly.
  • If deemed necessary, a disciplinary investigation is initiated; and if necessary, cooperation is made with the relevant authorities.
  • All parties are protected during the investigation process.
  • If non-compliance is detected, all necessary actions, including disciplinary sanctions, contract termination, compensation obligations, and legal proceedings, shall be implemented.

7. Preventive Measures

The University mitigates the risks of corruption and irregularities through the following mechanisms:

  • Clear definition of authorization and approval mechanisms,
  • Implementation of double signature and control processes,
  • Transparent evaluation of procurement and contract processes,
  • Risk analyses and audit activities,
  • Ethical compliance declarations and detailed company investigation processes for third parties,
  • Process-based checklists, documentation, and logging requirements.

8. Third-Party Relationships

  • All suppliers, subcontractors, consultants, and other third parties working with the University agree in writing to abide by this policy.
  • Bribes, commissions, gifts, benefits, or any other illegal demands from third parties are unacceptable.
  • Transparent, equitable, and objective criteria are exercised in supplier selection.
  • University employees may not accept any gifts, payments, commissions, entertainment, donations, or benefits that could influence or create the perception that they influence their duties.
  • All donations made on behalf of the University are received through institutional channels and through open registration.