Anti-Corruption Policy (Implementation of ISO 37001:2016 Standard)

About this Policy:

STARS International University®'s policy is to conduct all of our business in an honest and ethical manner. We have a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships.

Any employee of STARS International University® who breaches this policy will be subject to disciplinary action, which may include dismissal for gross misconduct. Any non-employee who breaches this policy (or where we have reasonable suspicion of such a breach) may have their contract terminated immediately.

This policy does not form part of any employee's contract of employment and we reserve the right to amend it at any time.

Who is obliged to comply with this policy?

This policy applies to all persons working for us or on our behalf in any capacity, including employees of all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

What is bribery?

Bribery is the giving or receiving of a financial or other advantage for the performance of a function that is illegal, unethical, a breach of trust, or improper. Bribes can include money, gifts, loans, fees, hospitality, services, discounts, the awarding of a contract, or any other advantage or benefit.

Bribery includes offering, promising, giving, accepting, or seeking a bribe.

All forms of bribery are strictly prohibited.

In particular, you must not:

1. give or offer payment, gift, hospitality, or other advantage with the expectation of receiving a business advantage in return or as a reward for a favour granted;
2. accept an offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else;
3. give or offer payment (sometimes referred to as a "facilitation payment") to an official in any country to speed up or simplify a standard or necessary procedure;
4. threaten or retaliate against another person who has refused to give or accept a bribe or has raised concerns about potential bribery or corruption.

Gifts and Hospitality:

This policy does not prohibit giving or receiving reasonable and appropriate hospitality for legitimate purposes, such as building business relationships or maintaining the image of STARS International University®.

A gift or hospitality will not be considered appropriate if it is excessively lavish or could be perceived as an inducement or reward for any preferential treatment (e.g., during contract negotiations or a tender process).

Gifts should be proportionate to the circumstances, of an appropriate type and value, and consider the reason for their provision. Gifts should not include cash or cash equivalents (e.g., vouchers) and should not be given secretly. All gifts should be given on behalf of STARS International University®, not on your personal behalf.

Record Keeping:

You are required to declare and keep a written record of all gifts or hospitality given or received.

You must also submit all expense claims relating to hospitality, gifts, or third-party payments in accordance with our expenses policy and record the reasons for such expenditure.

All invoices, receipts, and other records relating to dealings with third parties, including suppliers, must be prepared with strict accuracy and completeness. The creation of "off-book" accounts to conceal or facilitate improper payments is prohibited.

International Certification:

In addition to the implemented ISO 9001:2015 Quality Management System standard, STARS International University® is currently working on the implementation of an Anti-Bribery Management System in accordance with the international standard ISO 37001:2016.