Anti-Corruption and Anti-Bribery Principles

International Academy
Jul 15
3 min read

1. Introduction and Statement of Commitment

Swiss International University (SIU) upholds an unwavering commitment to the principles of integrity, transparency, and lawful conduct in all its academic, administrative, and operational functions. As a globally active institution, SIU operates across jurisdictions with differing legal environments, yet remains unified in its commitment to a zero-tolerance approach to corruption, bribery, fraud, and organized crime.

Corruption undermines education, erodes trust in institutions, and diverts resources from students and communities. In alignment with Sustainable Development Goal 16: Peace, Justice and Strong Institutions, this policy provides a formal structure for preventing, detecting, and responding to any form of corruption within the university environment.

2. Scope of Application

This policy applies to all members and affiliates of the university, including:

Full-time and part-time faculty and staff
Students at all academic levels
Visiting lecturers and scholars
Contractors, vendors, and external consultants
Governing board members and institutional partners

This policy covers all university activities globally, including education delivery, research, procurement, partnerships, accreditation relations, hiring, and student services.

3. Definitions

To support clarity and consistency, the following definitions apply:

Bribery: Offering, giving, receiving, or soliciting anything of value (financial or non-financial) with the intent to improperly influence a person’s actions or decisions.
Corruption: Abuse of entrusted power for personal or institutional gain, including favoritism, kickbacks, embezzlement, or nepotism.
Organized Crime: Involvement in or facilitation of criminal networks or enterprises, including money laundering or trafficking.
Facilitation Payments: Small, unofficial payments to expedite routine actions or services. SIU prohibits all facilitation payments regardless of local custom.

4. Principles and Standards

4.1 Zero Tolerance

SIU prohibits any form of bribery, corruption, or illicit conduct, whether carried out directly or through third parties. Any individual or entity found engaging in such behavior will face serious disciplinary measures, including termination of employment, expulsion, contract annulment, and legal prosecution where applicable.

4.2 Ethical Conduct and Professional Integrity

All members of the university community are expected to act with honesty, transparency, and fairness. Academic, financial, and administrative decisions must be guided solely by merit and institutional interest, free from undue influence.

4.3 Legal Compliance

SIU strictly adheres to applicable anti-corruption and anti-bribery laws in all jurisdictions where it operates, including:

Swiss Criminal Code (Articles 322 et seq.)
UAE Federal Anti-Corruption Law
Kyrgyz Law on Combating Corruption
International instruments such as the UN Convention against Corruption and OECD Anti-Bribery Convention

4.4 Transparent Procurement and Contracting

Procurement of goods, services, and partnerships must follow documented procedures that ensure fairness, competition, and value for money. Any conflicts of interest must be declared, and selection processes must be auditable.

4.5 Gifts and Hospitality

Staff and students may not accept or offer gifts, entertainment, or hospitality that could influence—or appear to influence—decisions. Exceptions may apply for symbolic or customary tokens, subject to prior written approval and declaration.

5. Reporting and Whistleblower Protection

5.1 Reporting Channels

Suspected breaches of this policy must be reported through one of the following confidential channels:

Internal reporting form (via staff/student intranet)
Direct contact with the Compliance Officer or designated ethics personnel

5.2 Protection of Whistleblowers

Whistleblowers who act in good faith will be protected from retaliation, academic penalty, or disciplinary measures. SIU guarantees confidentiality and ensures reports are investigated fairly, thoroughly, and without prejudice. Malicious or knowingly false reports will be subject to disciplinary action.

6. Investigations and Enforcement

The Internal Audit and Compliance Unit is responsible for investigating reports of corruption or bribery.
Findings will be reviewed by the senior leadership team, and appropriate sanctions will be imposed.
Where required by law, cases will be reported to external authorities.
Repeated or systemic breaches may trigger institutional reviews and remedial action plans.

7. Education and Awareness

All employees, including senior management, must complete mandatory anti-corruption training annually.
New students and staff receive induction training on institutional ethics and reporting procedures.
Periodic workshops and communication campaigns reinforce a culture of integrity.

8. Oversight and Review

The Office of Compliance and Risk Management is responsible for:

Monitoring adherence to this policy
Reviewing and updating this policy annually
Publishing an Annual Integrity and Ethics Report summarizing activities, breaches, and improvements

9. Public Commitment and Accessibility

This policy shall be publicly available on the university website and included in: