1. Introduction

The University of Chittagong is committed to maintaining the highest standards of integrity and ethical values in all its operations and activities. It expects everyone associated with the university to conform to this commitment. Recognizing the pervasive and longstanding problem of corruption in Bangladesh and the inadequacies in enforcing anti-corruption laws, the University has a zero-tolerance stance against all forms of bribery and corruption. This updated Anti-Bribery and Anti-Corruption Policy aims to prevent bribery or corruption and ensure fairness and institutional integrity. This policy applies to all employees and anyone else acting on behalf of the university. It builds upon the university’s existing ‘Anti-bribery Policy’. It considers the legal backdrop and institutional anti-corruption system of Bangladesh, as well as international best practices.

1. Scope and Applicability

This policy applies to all individuals associated with the University of Chittagong, including but not limited to:

• All employees (faculty, administrative staff, and other staff members).
• Members of the University’s governing bodies (e.g., Syndicate, Senate, Academic Council, if applicable).
• Students.
• Visiting scholars and researchers.
• Contractors, consultants, service providers, and suppliers acting for or on behalf of the University.
• Agents, representatives, and any third parties acting on the University’s behalf.
• Alumni in their interactions with the University on official matters.

III. Definitions

The following definitions shall apply for this policy:

• Anti-Bribery Laws means all Applicable Laws relating to anti-bribery, anti-corruption, or anti-kickbacks, which may include the Prevention of Corruption Act, 1947 of Bangladesh, Money Laundering Prevention Act, 2012, the Bangladeshi Penal Code, 1860, Anti-Corruption Commission Act, 2004, and any other Applicable Laws in any jurisdiction.
• Applicable Laws means concerning any person or thing, any supranational, national, municipal or local law, common law, regulation, directive, guideline, constitution, act of parliament, ordinance, treaty, convention, by-law, circular, guidance, notice, code, rule, order, injunction, judgment, decree, arbitral award, ruling, finding, statute, ordinance or other similar requirement enacted, adopted, promulgated or applied by an Authority.
• Authority includes any supranational, national, state, municipal or local government, governmental, semi-governmental, intergovernmental, regulatory, judicial or quasi-judicial body, agency, department, entity or authority, stock exchange or self-regulatory organization established under statute and shall include persons exercising executive, legislative, judicial, regulatory or administrative functions of or about government.
• Bribery is offering, giving, soliciting, or accepting any gratification or financial or other advantage, directly or indirectly, as an inducement or reward for doing or forbearing to do any act or for showing or forbearing to show favor or disfavor to any person in relation to the University’s operations.
• Gratification and financial or other advantage include facilitation payments, assets, benefits, loans, employment, agreement to render services, release, discharge of any liability, money, forbearance to demand money, forbearance from exercising any right or power, obtaining favorable treatment or improper commercial advantage, gifts, entertainment, favors, services or benefits, commission, valuable consideration of any kind and any service or favor. A gift includes all forms of entertainment, travel, hospitalities, donations, and sponsorships.
• Politically Exposed Persons (PEPs) include any government official, any official of government departments, agencies, or instrumentalities, any official or employee of public international organizations, political party official or candidate for political office, any employee of a public body, any employee of a state-owned or controlled entity, or their respective representatives or proxies.

1. Prohibited Conduct

The following activities are strictly prohibited under this policy:

• Offering, giving, promising, or authorizing the giving of any bribe or gratification to any person or entity, whether in the public or private sector, including but not limited to:
  • University employees, students, or governing body members.
  • Government officials or Politically Exposed Persons (PEPs).
  • Officials or employees of other educational institutions, research organizations, or private sector entities.
  • Agents, contractors, suppliers, or other third parties doing business with or seeking to do business with the University.
• Soliciting or accepting any bribe or gratification from any person or entity in exchange for any action or inaction related to the University’s operations.
• Facilitation Payments: Making small, unofficial payments to expedite routine governmental actions is prohibited.
• Kickbacks: Offering, giving, soliciting, or receiving any payment or benefit as a return for a favour or improper influence related to university activities are prohibited.
• Extortion: Demanding or obtaining any bribe or gratification through coercion or intimidation is strictly prohibited.
• Improper Gifts, Hospitality, and Entertainment: Offering or accepting gifts, hospitality, or entertainment that could be perceived as intended to influence decision-making improperly. Modest and reasonable hospitality or promotional gifts may be acceptable if they are transparent, infrequent, and do not create an obligation or appearance of impropriety. Guidelines on acceptable gifts and hospitality may be provided separately.
• Conflicts of Interest: Engaging in any activity or having any personal interest that could improperly influence the performance of university duties. All potential conflicts of interest must be declared and managed following the University’s Conflict of Interest Policy (proposed).
• Use of University Resources for Private Gain: Using University funds, assets, or information for personal benefit or the benefit of others in exchange for undue influence or gain.
• Failure to Report: Failing to report any suspected incident of bribery or corruption under this policy.
• Retaliation: Taking any adverse action against anyone who reports a suspected incident of bribery or corruption in good faith.

1. Reporting Procedures and Whistleblower Protection

The University has established procedures for reporting any suspected incident of bribery or corruption. All members of the university community are encouraged to report any concerns or suspicions regarding bribery or corruption to the designated authority.

• Reporting Channels: Suspected incidents of bribery or corruption should be reported to the Proctor of the University of Chittagong and/or through additional reporting channels, including designated members of the University’s administration (e.g., Vice-Chancellor, Registrar, Student Advisor office, Anti-harassment committee, Head of the relevant department/faculty) or a confidential reporting mechanism (e.g., Complaint Boxes, Ethics hotline (proposed).
• Reports can be made in person, in writing, or through any designated channel.
• All reports will be treated with confidentiality to the greatest extent, consistent with the need to conduct a thorough investigation.
• Whistleblower Protection: The University protects individuals who report suspected bribery or corruption in good faith from retaliation, intimidation, or harassment. Any act of retaliation against a whistleblower will be treated as a serious violation of this policy and subject to disciplinary action.
• The University encourages the reporting of concerns to the Anti-Corruption Commission (ACC) of Bangladesh or platforms like Transparency International Bangladesh’s (TIB) “Report Corruption” initiative (www.ti-bangladesh.org/rc), in addition to internal reporting mechanisms.

1. University’s Internal Reward System

The University shall consider the following internal reward mechanisms for individuals who demonstrate exceptional commitment to anti-bribery and anti-corruption principles to foster a culture of integrity and encourage adherence to this policy:

• Formal Recognition:
  • Letters of commendation from the Vice-Chancellor or relevant University authorities for employees or students who proactively prevent bribery or corruption.
  • Public acknowledgment of individuals who report incidents of bribery or corruption in good faith, where appropriate and with the individual’s consent.
  • Inclusion of ethical conduct and anti-corruption efforts in performance evaluations for employees.
• Opportunities for Professional Development:
  • Relevant training programs, workshops, or conferences on ethics, compliance, and anti-corruption should be given priority to individuals who actively promote and uphold this policy.
  • Opportunities for involvement in initiatives to strengthen the University’s ethical framework and anti-corruption measures.
• Merit-Based Incentives (within existing University regulations):
  • Consideration for merit-based awards or recognition for employees who consistently demonstrate high ethical standards and contribute to a corruption-free environment.

VII. University’s Internal Disciplinary Actions

Any violation of this Anti-Bribery and Anti-Corruption Policy will be taken seriously and may result in disciplinary action as per the University’s rules and guidelines, in addition to any potential legal consequences under the laws of Bangladesh. The severity of the disciplinary action will depend on the nature and seriousness of the violation and may include:

• • For Employees, the corrective and punitive options under the University’s rules of business may include a Verbal or written warning, Placing a formal reprimand in the employee’s personnel file, Suspension without pay, Demotion, or Termination of employment.
  • For Students, corrective actions may include Verbal or written warning, Suspension from academic activities, Expulsion from the University, Revocation of degree or certificate, and others as per the university’s rules of business.
  • For Contractors, Consultants, Service Providers, Suppliers, and Third Parties, the corrective and punitive actions may include Termination of the contract or agreement, Being barred from future business with the University, and Reporting the violation to relevant external authorities.
  • For Members of Governing Bodies, punitive and corrective measures may include referring the matter to the relevant internal disciplinary committee or authority for appropriate action, as per University statutes and regulations.

The University will cooperate fully with any investigations conducted by the Anti-Corruption Commission (ACC) or other law enforcement agencies in Bangladesh regarding bribery and corruption offenses.

VIII. Responsibilities

• University Leadership: The University’s leadership is responsible for promoting a culture of integrity and ensuring the effective implementation of this policy.
• Heads of Faculties, Departments, and Administrative Units are responsible for ensuring that all individuals within their units know and comply with this policy.
• All Individuals Covered by this Policy are responsible for understanding and adhering to this policy and reporting any suspected violations.
• The Proctorial Body is the primary contact for reporting suspected incidents of bribery or corruption. It is responsible for initiating preliminary investigations and referring matters to the appropriate authorities.
• The University’s Legal Office will provide guidance on legal matters related to this policy and will liaise with external legal authorities as necessary.
• The Institutional Quality Assurance Cell (IQAC) may monitor and review the effectiveness of this policy as part of the university’s overall quality assurance framework.

1. Training and Awareness

The University will provide regular training and awareness programs to all members of the university community on this Anti-Bribery and Anti-Corruption Policy, including:

• The definition of bribery and corruption.
• Examples of prohibited conduct in the university context.
• Reporting procedures and whistleblower protection.
• The consequences of violating this policy.

These programs will cultivate a culture of ethical conduct and ensure that all individuals are equipped to identify and address bribery and corruption risks.

1. Review and Updates

This policy will be reviewed and updated periodically, at least every two years, or as necessary, to ensure its effectiveness and alignment with changes in legislation, best practices, and the University’s evolving needs. The review process will involve relevant stakeholders within the University community.