Anti-corruption Policy

About this policy

STARS International University® policy is to conduct all our activities honestly and ethically. We adhere to the principle of zero tolerance for bribery and corruption and strive to act professionally, fairly, in accordance with the laws of the Republic of Uzbekistan and in accordance with international standards, in all our business transactions and relationships.

Any STARS International University® employee who violates this policy will be subject to disciplinary action, which may include dismissal for gross misconduct. Any non-employee who breaches this policy (or if we reasonably suspect that they have) 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 change it at any time.

Who must comply with this policy?

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

What is bribery?

Bribery is the giving or receiving of financial or other consideration for an action that is illegal, unethical, in breach of trust or improper. Bribes may include money, gifts, loans, fees, hospitality, favours, discounts, award of a contract or any other advantage or benefit.

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

All forms of bribery are strictly prohibited.

In particular, you must not:

give or offer a payment, gift, hospitality or other advantage with the expectation of receiving a business advantage in return or as a reward for the advantage received; 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 someone else; give or offer a payment (sometimes called a "facilitation payment") to a public official in any country to expedite or simplify a routine or necessary procedure; threaten or retaliate against another person who has refused to give or accept a bribe or has expressed concern about possible bribery or corruption.

Gifts and Hospitality

This policy does not prohibit the giving or acceptance of reasonable and appropriate hospitality for legitimate purposes, such as establishing 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 (for example, during contract negotiations or a tender process).

Gifts must be appropriate to the circumstances, of a suitable type and value, and take into account the reason for giving them. Gifts must not include cash or cash equivalents (e.g. vouchers) and must not be given in secret. All gifts must be given on behalf of STARS International University® and not on your 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 claims for reimbursement of expenses related to hospitality, gifts or payments to third parties in accordance with our Expense Policy and record the reasons for such expenses.

You must also submit all claims for reimbursement of expenses related to hospitality, gifts or payments to third parties in accordance with our Expense Policy and record the reasons for such expenses. All invoices, delivery notes and other records related to interactions with third parties, including suppliers, must be prepared with strict accuracy and completeness. Maintaining "unregistered" accounts to conceal or facilitate improper payments is prohibited.

International Certification

In addition to the implemented quality management standard ISO 9001:2015, STARS International University® is currently working on the implementation of an anti-corruption and bribery prevention management system in accordance with the international standard ISO 37001:2016.