ANTI-BRIBERY POLICY
1.0 Definitions
1.1 The following words and expressions have the meaning hereby assigned to them:
1.1.1 Bribe: The act of intentionally offering, promising, or giving an undue advantage, directly or indirectly, to an individual, or requesting, agreeing to receive, or accepting an undue advantage, directly or indirectly, by an individual, or any other person who holds a legislative, administrative, or judicial office, for that person or another person to act or refrain from acting in the exercise of their official duties, or to act or refrain from acting in the exercise of something that does not fall within their duties, but which they mistakenly believe or claim it does.
1.1.2 Employee: Any person with an employment contract directly with the University.
1.1.3 Student: A person who is presently enrolled at the University in a Credit Course or who is designated by the University as a Student.
1.1.4 Staff: Person(s) employed by the University as Academic Members, or for providing administrative or technical support.
1.1.5 University: University of Doha for Science and Technology, established by Emiri Resolution No. 13 of 2022.
1.1.6 University Community: Staff and Students.
1.2 Where the context requires, words importing the singular shall include the plural and vice-versa.
1.3 Where a word or phrase is given a particular meaning, other parts of speech and grammatical forms of that word or phrase have corresponding meanings.
2.0 Policy Purpose
2.1 This policy aims to:
2.1.1 Affirm the University’s commitment to maintaining a culture of honesty, integrity, transparency, and accountability, and to preventing bribery and corrupt practices in all its operations and activities.
2.1.2 Set out University responsibilities for addressing Bribery-related issues.
3.0 Policy Scope
3.1 This Policy applies to:
3.1.1 University Employees, Students, contractors, suppliers, and any other individuals or entities associated, partnering, or collaborating with the University.
3.1.2 All aspects of the University’s operations, and any activities conducted for, or on its behalf.
4.0 Policy Statements
4.1 University prohibits all forms of Bribing in all its dealings and activities, whether financial or non-financial, to or from any person or entity, whether public or private.
4.2 Principles of the Policy
The following principles apply in all aspects of the University’s operations, and are to be adhered to by everyone subject to this policy:
4.2.1 All members of the University Community are expected to uphold the highest standards of ethical conduct in their interactions, both within and outside the University.
4.2.2 University promotes transparency, integrity, accountability, and compliance with applicable laws and regulations related to anti-bribery and corruption, in all its dealings and activities.
4.2.3 University maintains a zero-tolerance approach to Bribery.
4.2.4 Due diligence is conducted to assess and mitigate Bribery risks in all the University’s dealings and activities.
4.2.5 Employees must adhere to the University’s gifting and hospitality-related policies and procedures.
4.3 Breaches of the Policy
4.3.1 University will vigorously enforce compliance with this Policy and any violations may result in disciplinary action, including termination of employment or dismissal, and reporting to law enforcement for legal proceedings, as per applicable policies and procedures.
4.3.2 Third parties who have offered or accepted bribes must not be engaged to work for or provide services to the University.
4.4 Reporting and Whistle Blowing
4.4.1 University encourages all to whom this Policy applies to report any violation concerns immediately. All reporting will be handled sensitively.
4.5 Record-keeping
4.5.1 Appropriate internal controls will be put in place, through relevant procedures, to evidence the business reason for making payments to third parties.
4.5.2 All hospitality or gifts accepted or offered must be declared and recorded in writing, subject to the relevant procedures.
4.5.3 All accounts, invoices, memoranda, and other documents and records relating to dealings with third parties must be prepared and maintained with strict accuracy and completeness in adherence to International Financial Reporting Standards (IFRS). No accounts must be kept "off-book" to facilitate or conceal improper payments.
5.0 Procedures
5.1 The President will ensure that related procedures are developed for the implementation of this Policy.
6.0 Related Documents
6.1 Law No. (15) of 2016 Promulgating the Civil Human Resources Law
6.2 Human Resources Policy (PL-NR-01)
6.3 Student Policy of Conduct
6.4 Procurement Policy
6.5 Finance Policy