KADIR HAS UNIVERSITY ANTI-FRAUD, BRIBERY, CORRUPTION, AND ORGANIZED CRIME POLICY
Kadir Has University (KHAS) is committed to maintaining the highest ethical standards, and all activities carried out within the university are expected to be conducted with honesty, fairness, and transparency. In accordance with the Constitution of the Republic of Turkey, all forms of bribery, corruption, or any attempt to secure an unfair advantage are strictly prohibited and will not be tolerated.
A culture founded on integrity is actively promoted and safeguarded throughout KHAS’s academic, administrative, and operational practices. It is required that all members of the university community, including academic and administrative staff as well as students, adhere to these principles. No individual should be placed in a position where unethical or dishonest actions allow them to benefit.
Scope
This policy applies to:
- All KHAS employees, regardless of role,
- Students of KHAS,
- Members of the university’s governing bodies, councils, and committees,
- Any individuals or organizations authorized to act on behalf of, or represent, KHAS in any capacity.
Definitions
- Bribery: Offering, giving, soliciting, or receiving of any item of value as a means of influencing the actions of an individual holding a public or legal duty.
- Corruption: Corruption is the abuse of entrusted power for private gain that harms the public interest, typically breaching laws, regulations, and/or integrity standards.
Policy Objectives
The objectives of this policy are to:
- Ensure that KHAS operates in full compliance with national and international anti-bribery and anti-corruption laws.
- Promote and sustain a culture of transparency, accountability, and zero tolerance for bribery and corruption within the university.
- Provide clear and practical guidelines to help identify, prevent, and report any instances of bribery and corruption.
- Safeguard the reputation of KHAS and reinforce its commitment to the highest standards of ethical conduct.
- Establish preventive mechanisms to detect and minimize risks of bribery and corruption.
- Enhance awareness through training and ensure protection for those who report misconduct in good faith.
Policy Principles
- Prevention of Bribery and Corruption: KHAS is committed to implementing proactive measures to prevent bribery and corruption. This includes conducting regular risk assessments, establishing monitoring systems, and fostering a culture of awareness among all employees and students.
- Prohibition of Bribery: No KHAS employee, student, or individual acting on behalf of the university may offer, promise, give, solicit, or accept any form of bribe, whether financial or otherwise, to influence decisions or gain undue advantage.
- Prohibition of Corruption: All forms of corruption are strictly prohibited at KHAS, including but not limited to:
- Fraud
- Embezzlement
- Facilitation payments
- Any abuse of power for personal or institutional gain
- Transparent and Fair Practices: All university operations are to be conducted in a fair and transparent manner. This includes procurement processes, contract management, and interactions with external parties. Clear documentation, accurate financial reporting, and proper record-keeping must be maintained to ensure accountability.
- Reporting Bribery and Corruption: All employees and students are required to report any suspicion or knowledge of bribery or corruption. Reports can be made to the Directorate of Financial Affairs or through designated confidential channels.
- All reports will be investigated thoroughly and impartially.
- Whistleblowers’ identities will be protected, and retaliation against individuals reporting in good faith will not be tolerated.
- Investigations and Enforcement: All allegations of bribery or corruption will be investigated in accordance with KHAS’s Financial Regulations and relevant disciplinary procedures. Confirmed violations will result in appropriate disciplinary actions, which may include:
- Termination of employment for staff
- Expulsion for students
- Legal proceedings where applicable laws have been violated
- Penalties for Violations: Violations of this policy by KHAS employees or students are considered serious offenses. Severe disciplinary measures, including dismissal or expulsion, may be applied. Violations may also be reported to relevant legal authorities, potentially resulting in criminal prosecution.
Responsibilities
- University Leadership: The Rector, Vice Presidents, Deans, and Department Directors are responsible for promoting a culture of ethical behavior and ensuring that the Anti-Bribery and Corruption Policy is fully implemented and observed throughout KHAS.
- Employees and Students: All employees and students of KHAS are individually responsible for complying with this policy. This includes avoiding any actions that could constitute a violation and reporting any suspected incidents promptly.
- External Parties: Any individuals formally acting on behalf of KHAS must comply with this policy and are expected to uphold the university’s standards of integrity in all dealings.
Training and Communication
KHAS will provide continuous training to all employees and students to ensure that they are fully aware of their responsibilities under this policy. Efforts will also be made to communicate the university’s position on bribery and corruption, as well as the procedures for reporting any suspected violations, to all relevant parties.
Review and Monitoring
This policy will be reviewed on a regular basis to ensure its continued effectiveness. Compliance with the policy will be monitored by KHAS’s internal audit teams, and any necessary updates will be implemented in accordance with changes in national or international legislation.
Conclusion
Kadir Has University is committed to operating in a transparent, honest, and ethical manner. All members of the KHAS community are expected to uphold these principles and contribute to an environment in which bribery and corruption are not tolerated. Any non-compliance will be addressed through appropriate measures to protect the university’s integrity and reputation.

Kadir Has University upholds the United Nations Global Compact’s Tenth Principle, which states that “businesses should work against corruption in all its forms, including extortion and bribery.” In alignment with this universal commitment, the University maintains a strong stance against all forms of corruption, bribery, and unethical conduct in its academic, administrative, and financial activities.
We continuously promote a culture of transparency, accountability, and integrity across all levels of the institution. Our internal policies and practices are designed to prevent conflicts of interest, ensure responsible governance, and foster ethical decision-making.
Kadir Has University reaffirms its commitment to these global principles through regular monitoring, reporting, and improvement of its governance framework. This dedication was also highlighted in our 2023–2024 Progress Report, which details the University’s ongoing efforts to uphold ethical standards and good governance practices.