Anti Bribery and Corruption Policy

(Reviewed: 2022)
Introduction
Lovely Professional University (LPU) is committed to upholding the highest standards of integrity, transparency, and ethical conduct in all its operations. The University recognizes the importance of combating bribery and corruption to maintain an environment of trust, fairness, and equal opportunity for all its stakeholders. In line with the Indian legal framework and international best practices, LPU has developed this Anti-Bribery and Corruption Policy to outline its unequivocal stance against any form of bribery, corruption, or unethical behaviour.

Bribery and corruption are serious offenses that undermine the principles of fairness, trust, and meritocracy. They distort competition, compromise decision-making processes, and erode public confidence. LPU is firmly committed to preventing such practices and maintaining a level playing field for all the stakeholders of the University.

This policy aligns with LPU's broader commitment to good governance, ethical conduct, and the promotion of integrity in all its activities. It reflects the University's dedication to creating a transparent and accountable environment where individuals are encouraged to report any suspicions or concerns related to bribery or corruption without fear of reprisal.
Scope

The scope of Lovely Professional University's (LPU) Anti-Bribery and Corruption Policy extends to all individuals and entities associated with the University, including but not limited to employees, students, contractors, suppliers, agents, consultants, volunteers, and any other external parties engaged in activities on behalf of LPU.

This policy applies to all activities conducted by or on behalf of LPU, irrespective of the location or jurisdiction in which they occur. It encompasses interactions with government officials, business partners, vendors, students, and any other stakeholders within the University's sphere of influence.

Key Policy Principles
  1. Prohibition of Bribery and Corruption: LPU strictly prohibits the offering, giving, receiving, or soliciting of gifts, bribes, kickbacks, or any other improper advantages to gain an unfair advantage in business or decision-making processes. All forms of bribery, whether financial or non-financial, are strictly forbidden.
  2. Compliance with Laws and Regulations: LPU is committed to complying with all applicable anti-bribery and corruption laws, regulations, and international standards. The University expects all individuals associated with it to abide by these laws and act in accordance with their spirit, irrespective of the jurisdiction in which they operate.
  3. Prevention and Risk Assessment: The University will implement proactive measures to prevent bribery and corruption, including conducting regular risk assessments to identify potential vulnerabilities and areas of concern. Mitigation strategies will be developed and implemented to minimize the risk of bribery and corruption.
  4. Due Diligence and Controls: The University shall exercise due diligence in selecting, engaging, and monitoring business partners, contractors, and suppliers to ensure their commitment to ethical conduct and compliance with anti-bribery and corruption standards. The University aims to establish robust controls and procedures to detect and prevent any improper activities.
  5. Awareness and Training: LPU shall provide regular awareness programs and training to educate all stakeholders of the University about the risks and consequences of bribery and corruption. Such programs will promote a culture of integrity, ethics, and responsible behaviour, empowering individuals to recognize and report any suspected or actual instances of bribery and corruption.
  6. Reporting and Investigation: LPU encourages the reporting of any concerns or suspicions related to bribery and corruption. The University has established confidential and accessible reporting channels, ensuring protection for whistle-blowers. Reported incidents are promptly and thoroughly investigated, and appropriate disciplinary and legal actions are taken accordingly.
  7. Continuous Improvement: LPU is committed to regularly reviewing and updating its Anti-Bribery and Corruption Policy to ensure its effectiveness and relevance. The University shall learn from past experiences, industry best practices, and emerging trends to enhance its anti-bribery and corruption measures continually.
Coverage
  1. The Anti-Bribery and Corruption Policy covers various forms of bribery and corruption, including but not limited to:
  2. Financial bribes or kickbacks: Offering, giving, receiving, or soliciting money, gifts, loans, services, or any other form of financial advantage to influence or gain an improper advantage in business or decision-making processes.
  3. Improper benefits and advantages: Providing or accepting non-financial benefits, such as lavish hospitality, favours, excessive entertainment, or other perks that may compromise objectivity or integrity.
  4. Extortion and coercion: Demanding or forcing individuals or entities to provide money, assets, or other valuables through threats, intimidation, or misuse of power.
  5. Facilitation payments: Making small, unofficial payments to expedite routine or necessary actions, even if they are customary or expected in a particular country or culture.
  6. Nepotism and favouritism: Engaging in unfair practices that grant undue advantages or preferences to friends, family members, or individuals with personal relationships, without considering merit or qualifications.
  7. Money laundering: Engaging in transactions or activities aimed at disguising the origins or true nature of illicit funds or assets.
Restricted Practices
  1. Illustrative List of acts /practices which are restricted / prohibited under the policy framework is given below:
    1. Dishonest misappropriation of property/money as defined under Indian Penal Code (IPC)
    2. Criminal breach of trust, as defined by the IPC.
    3. Cheating, as defined by the IPC.
    4. Giving or receiving bribes.
  2. Offering gifts, whether in cash or non-cash form and in any currency, on behalf of the Organization, its employees, and representatives to third parties, is not permitted.
  3. Engaging in charitable activities solely for obtaining commercial advantages is prohibited.
  4. Any unethical act or omission is not allowed.
  5. Utilizing partners, agents, joint ventures, intermediaries, or other individuals for actions that contradict the principles and requirements of the Policy or the regulations of applicable anti-corruption laws is prohibited.
  6. Exercising the principle of due diligence and controls, no false or misleading entries should be made in any books or financial records of the LPU for any reason whatsoever. Any expenses that an employee or third party incurs on LPU’s behalf or in connection with our organization shall be reimbursable only when supported by detailed documentation including, for example, valid invoices or receipts.
Ramifications of Misconduct

Lovely Professional University (LPU) takes any form of bribery or corruption very seriously and is committed to enforcing strict consequences for misconduct. Any individual found to be in violation of LPU's Anti-Bribery and Corruption Policy may face significant ramifications, including disciplinary action, legal consequences, and damage to their reputation and relationship with the University.

How to make a complaint

The University has created an efficient and transparent Relationship Management System (RMS), which is an online module available on University Management System (UMS) where the employees of the University can share their grievances /queries/suggestions related to any issue they are facing while working in the University.

This provision generates transparency of operations, time bound redressal of the issues raised by the employees and continuous upgradation of systems, procedures and policies.

Online Office Management System (OMS) is another interface wherein the employee can seek appointment with the Registrar or the concerned authority and discuss his/her concerns in-person. Herein an opportunity is provided to the employees to put forward the issue, understand the existing policies and norms and seek the best possible resolution. A stakeholder may also opt to put his point forward via offline mode wherein he can share a written information with the necessary details in a sealed envelope with the Registrar of the University. If for any reason the stakeholder wishes to register his issue with some other authority (other than the Registrar) he/she can reach the Vice Chancellor for the same. The University is very open and receptive to any new direction or guidelines issued or endorsed by the regulatory authorities and immediately try to incorporate the same into the system.