Anti-Corruption, Anti-Bribery and Organized Crime Policy

Policy Statement

An-Najah National University (ANNU) is firmly committed to preventing and combating organized crime, corruption, bribery, fraud, and other forms of unethical or unlawful conduct across all its academic, administrative, financial, research, procurement, and operational activities.

The University adopts a zero-tolerance approach to bribery and corruption and prohibits any involvement in, facilitation of, or support for organized criminal activities. It is committed to upholding integrity, transparency, accountability, fairness, and the rule of law in all institutional decisions and relationships.

The University shall conduct its activities in accordance with applicable Palestinian legislation and relevant legal and regulatory requirements. These commitments form an integral part of the University's institutional governance, ethical standards, and responsibility toward its students, employees, partners, suppliers, public institutions, and the wider community.

Purpose

This policy establishes the University's institutional principles and commitments to prevent, identify, report, investigate, and address organized crime, bribery, and corruption. It aims to safeguard institutional integrity, protect University resources, maintain public trust, and ensure that institutional decisions are made fairly, transparently, and free from improper influence.

Scope

This policy applies to all members of the University community, including the Board of Trustees, University leadership, academic and administrative staff, researchers, students, contractors, suppliers, consultants, business partners, and other individuals or organizations acting on behalf of, representing, or conducting business with the University, as applicable.

Institutional Principles and Commitments

ANNU is committed to the following principles:

• Zero tolerance for bribery and corruption: Prohibiting the offering, giving, requesting, or accepting of bribes or improper benefits intended to influence institutional decisions or actions.

• Prevention of organized crime: Prohibiting the use of university facilities, resources, activities, partnerships, or institutional relationships to facilitate organized criminal activities, money laundering, fraud, illicit financial transactions, or other unlawful conduct.

 

• Integrity and accountability: Ensuring that institutional decisions and the use of university resources are guided by ethical conduct, responsible management, and clear accountability.

• Transparency and fairness: Promoting transparent decision-making and fair practices in procurement, recruitment, financial management, research administration, contracting, and partnerships.

• Compliance with applicable laws: Requiring compliance with relevant Palestinian legislation, institutional regulations, and applicable legal obligations concerning corruption, bribery, fraud, and organized crime.

• Responsible partnerships: Promoting ethical conduct and appropriate due diligence in dealings with suppliers, contractors, donors, commercial entities, and other external stakeholders.

• Protection of reporting persons: Providing appropriate confidential reporting channels and protecting individuals who report suspected misconduct in good faith from retaliation, in accordance with applicable policies and laws.

• Investigation and accountability: Ensuring that reported concerns are assessed and investigated fairly and impartially, and that substantiated violations are addressed through appropriate disciplinary, contractual, or legal measures.

• Awareness and prevention: Promoting awareness of the University's ethical standards and the responsibilities of its community and external stakeholders in preventing corruption, bribery, and organized crime.

Prohibited Conduct

The following conduct is prohibited within the scope of this policy:

• Offering, soliciting, giving, or receiving bribes or improper advantages.

• Misusing institutional authority, funds, property, or information for personal or improper gain.

• Engaging in fraud, embezzlement, money laundering, or other unlawful financial practices.

• Knowingly facilitating or supporting organized criminal activities through university resources, transactions, or institutional relationships.

• Concealing, obstructing the investigation of, or knowingly failing to disclose misconduct where disclosure is required by applicable rules or law.

• Retaliating against individuals who report suspected violations in good faith.

Responsibilities and Governance

• Board of Trustees

The Board of Trustees shall exercise its responsibilities concerning the approval and oversight of this policy in accordance with the University's governance framework and applicable rules.

• President of the University

• The President shall support the implementation of this policy, promote institutional compliance, and exercise the responsibilities assigned to the office under the University's governance arrangements.

• The President shall review and approve the policy in accordance with the applicable approval process and submit it to the Board of Trustees for consideration and formal approval as required by university procedures.

• Legal Affairs Office

The Legal Affairs Office shall be responsible for:

• Drafting this policy and proposed amendments.

• Reviewing the policy for consistency with applicable Palestinian legislation and the University's governance framework.

• Coordinating the policy review process with relevant University departments.

• Advising authorized University bodies on the interpretation and application of the policy.

• Recommending revisions when required by changes in legislation, institutional needs, or relevant compliance requirements.

• The Legal Affairs Office shall not replace the responsibilities of authorized investigative, disciplinary, auditing, or decision-making bodies.

• Internal Audit and Control Department

Within its approved mandate, the Internal Audit and Control Department shall contribute to assessing internal controls, identifying relevant institutional risks, and recommending improvements to strengthen accountability and reduce opportunities for fraud, corruption, and financial misconduct.

• Administrative Audit and Control Department

Within its approved mandate, the Administrative Audit and Control Department shall contribute to monitoring administrative compliance, identifying relevant irregularities, and recommending corrective measures in accordance with university procedures.

• Financial, Procurement, and Other Relevant Departments

Relevant departments shall implement appropriate controls within their areas of responsibility, maintain required records, identify and report suspected irregularities, and cooperate with authorized reviews and investigations.

• Deans, Directors, and Department Heads

Deans, directors, and department heads shall communicate the policy to relevant personnel, promote compliance within their units, and refer suspected violations through the appropriate reporting channels.

• Employees and Other Individuals Within Scope

All individuals covered by this policy shall:

• Act with integrity and comply with applicable rules.

• Avoid and disclose relevant conflicts of interest.

• Protect University resources and confidential information.

• Report suspected misconduct through appropriate channels.

• Cooperate with authorized investigations, subject to applicable rights and obligations.

• External Parties

Suppliers, contractors, consultants, partners, and other relevant external parties are expected to comply with applicable legal requirements and the ethical and contractual obligations governing their relationships with the University.

Reporting Suspected Violations

The University encourages individuals who become aware of suspected organized crime, bribery, corruption, fraud, or related misconduct within the scope of this policy to report their concerns through the University's designated reporting channels.

Reports may be submitted to the competent University authority or the relevant authorized oversight unit in accordance with established procedures.

A report should, where possible, include:

• A description of the suspected conduct.

• The relevant individuals, departments, transactions, or activities.

• The approximate date, time, or period involved.

• Supporting documents or other available information.

• Any other details that may assist in assessing the concern.

Individuals are not expected to conduct their own investigations or obtain evidence unlawfully before making a report.

Where a concern involves a person or unit ordinarily responsible for receiving reports, the reporting individual should use an alternative authorized channel, where available.

Suspected criminal conduct may be referred to the competent authorities where required or permitted by applicable law.

Confidentiality and Protection Against Retaliation

The University shall handle reports and related information confidentially to the extent reasonably possible and consistent with applicable law, the requirements of a fair investigation, and the rights of the individuals concerned.

Access to information shall be restricted to authorized individuals with a legitimate need to know.

The University shall not tolerate retaliation against individuals who report suspected misconduct in good faith, assist with authorized investigations, or exercise rights protected under applicable rules or law.

Anyone who believes they have experienced retaliation may report the matter through the University's designated reporting channels.

Knowingly submitting malicious or deliberately false allegations may itself constitute misconduct and may be addressed under applicable University procedures.

Assessment and Investigation

Reports of suspected violations shall be assessed by the appropriate authorized University body or official, according to the nature of the allegation and the University's established procedures.

Where an investigation is warranted, it shall be conducted fairly, impartially, and with due regard for confidentiality, the rights of the individuals concerned, and applicable legal requirements.

Investigations may involve reviewing relevant records, financial transactions, contracts, communications, or other evidence within the authority of the investigating body.

Individuals concerned shall be afforded appropriate procedural safeguards, including a fair opportunity to respond where required by applicable procedures.

No findings or disciplinary measures shall be imposed solely on the basis of an unverified allegation. Findings shall be based on the evidence and the applicable decision-making standards.

Where necessary, matters may be referred to the competent University authority or external authorities in accordance with applicable law.

Disciplinary Measures and Enforcement

Substantiated violations of this policy may result in appropriate measures, depending on the nature and seriousness of the conduct, the applicable legal framework, and the relevant University procedures.

Such measures may include:

• Corrective or administrative action.

• Disciplinary measures under applicable University regulations.

• Withdrawal of relevant authorizations or responsibilities, where permitted.

• Suspension or termination of contractual or business relationships in accordance with applicable agreements and law.

• Recovery of misused funds or assets, where legally appropriate.

• Referral to competent authorities for further action where required or warranted.

Any disciplinary or enforcement measure shall be imposed by the authorized body in accordance with applicable procedures and the rights of the individuals concerned.

Training, Communication, and Awareness

The University shall promote awareness of this policy and its principles among relevant members of the University community and external stakeholders.

Awareness activities may include:

• Communicating the policy through official University channels.

• Making the policy available to employees and relevant stakeholders.

• Providing guidance on bribery, corruption, conflicts of interest, and reporting procedures.

• Integrating relevant ethical and compliance requirements into applicable staff guidance, procurement processes, and contractual arrangements.

• Reviewing awareness needs based on identified risks and institutional experience.

The objective is to ensure that relevant stakeholders understand the University's commitments, recognize prohibited conduct, and know how to raise concerns appropriately.

Monitoring, Compliance, and Continuous Improvement

The University shall support the implementation and monitoring of this policy through its established governance, oversight, audit, and administrative arrangements.

Relevant units shall monitor compliance within their respective mandates and recommend improvements where weaknesses or risks are identified.

Monitoring may include reviewing reported concerns, internal control findings, relevant audit recommendations, and the effectiveness of reporting and response procedures.

Where appropriate, the University may use aggregated and non-identifying information to assess implementation and identify opportunities for improvement, subject to applicable confidentiality and data protection requirements.

The policy shall be reviewed periodically to ensure that it remains relevant, effective, and aligned with applicable legislation and institutional governance requirements.

Public Disclosure and Accessibility

An-Najah National University is committed to making its institutional principles and commitments concerning organized crime, corruption, and bribery publicly accessible.

Following formal approval, this policy shall be published on the University's official website and made available to employees, students, suppliers, institutional partners, and the wider public.

The University shall communicate its commitment to preventing and combating organized crime, bribery, and corruption through appropriate institutional channels.

The publicly available version shall accurately reflect the approved policy. Any subsequent amendments shall be reviewed and approved through the applicable governance process before publication.

The University may also communicate related ethical standards and compliance requirements through relevant internal regulations, staff guidance, procurement documentation, contractual arrangements, and awareness activities.

Policy Review and Amendment

The Legal Affairs Office shall be responsible for coordinating the periodic review and preparation of proposed amendments to this policy.

The policy shall be reviewed at least once every three years, or earlier where required by:

• Changes in applicable legislation or regulatory requirements.

• Changes in the University's governance structure or institutional responsibilities.

• Findings from audits, compliance reviews, or investigations.

• Identified weaknesses in existing controls or reporting mechanisms.

• The need to improve the effectiveness or clarity of the policy.

Proposed amendments shall be submitted to the President of the University and the Board of Trustees for review and approval in accordance with the University's established governance procedures.

Effective Date and Approval

This policy shall be drafted and reviewed by the Legal Affairs Office of An-Najah National University and submitted to the President of the University and the Board of Trustees for formal approval in accordance with established University governance procedures.

The policy shall enter into force on the effective date established through the formal approval process.

Upon approval, the University shall publish the policy on its official website and communicate it through appropriate institutional channels.

• Prepared by: Legal Affairs Office, An-Najah National University

• Reviewed by: President of An-Najah National University

• Approved by: Board of Trustees, An-Najah National University

Effective Date: December 12, 2018

Previous Update: March 7, 2022

Latest Update: Jun 23, 2025