Anti-Bribery and Anti-Corruption Policy

 

I. POLICY STATEMENT

Southern Leyte State University (SLSU), as a publicly funded institution of higher learning, affirms its unwavering commitment to upholding the highest standards of integrity, honesty, and transparency in the conduct of its academic, administrative, and financial affairs. Consistent with the principles enshrined in Republic Act No. 3019 (Anti-Graft and Corrupt Practices Act), Republic Act No. 6713 (Code of Conduct and Ethical Standards for Public Officials and Employees), and relevant international frameworks, SLSU adopts a zero-tolerance approach to all forms of bribery, graft, and corruption.

This policy aims to promote good governance, enhance public trust, safeguard institutional resources, and create a work and learning environment that is free from unethical practices. All employees, students, and stakeholders are expected to demonstrate behavior that reflects these values. Any attempt to offer, solicit, give, or receive bribes or improper advantages in any form is strictly prohibited and shall be dealt with through appropriate administrative and legal channels.

As part of its commitment to institutional excellence, this Anti-Bribery and Anti Corruption Policy establishes a robust framework of prevention, detection, and enforcement mechanisms. It seeks to integrate ethical practices into SLSU's culture by fostering awareness, providing clear guidance, and ensuring accountability at all levels of the organization.

II. SCOPE AND APPLICABILITY

This Policy applies to:

• All SLSU officials, faculty, staff, and employees (regular, contractual, casual, and part-time)
• Members of the Board of Regents  Student leaders and scholarship recipients
• Consultants, suppliers, contractors, grantees, service providers
• Any person or entity acting on behalf of SLSU

III. DEFINITIONS

1. Bribery – Offering, promising, giving, receiving, or soliciting anything of value as an inducement for action or inaction in the performance of a public duty.
2. Corruption – Misuse of public office or entrusted power for personal gain, including extortion, nepotism, fraud, embezzlement, collusion, and money laundering.
3. Public Officer – Any individual elected, appointed, or employed by SLSU receiving compensation for public service, as defined by RA 3019.
4. Gift – Anything of value including money, services, favors, hospitality, or employment.
5. Facilitation Payments – Small payments made to expedite routine government actions; these are strictly prohibited by SLSU.
6. Conflict of Interest – A situation in which personal interests interfere with the university’s interest or the impartial performance of official duties.

IV. PROHIBITED ACTS

Pursuant to Sections 3 and 4 of RA 3019, the following acts are prohibited:

1. Soliciting or Accepting Bribes – Directly or indirectly requesting or receiving gifts or benefits in connection with official duties.
2. Offering Bribes – Offering or promising anything of value to a public officer to influence an action.
3. Influence Peddling – Using personal relationships or positions to influence official actions.
4. Unjust Enrichment – Using one's position to unduly favor oneself or others in contracts, permits, or decisions.
5. Conflict of Interest – Participating in decisions where there is a direct or indirect personal or financial interest.
6. Improper Disclosure – Revealing or using confidential university information for personal gain.
7. Employment Abuse – Accepting employment from a private party that has official dealings with the university during or after such dealings.

V. GIFTS AND HOSPITALITY POLICY

Southern Leyte State University prohibits the offering, solicitation, and acceptance of gifts, hospitality, or other benefits that may create, or appear to create, a conflict of interest or exert undue influence on the recipient’s decision-making responsibilities. In accordance with Section 3 of RA 3019 and Section 7(d) of RA 6713, no public officer or employee shall directly or indirectly accept any gift, gratuity, favor, entertainment, or loan from any person or entity in connection with any transaction or business with the University.

Gifts may include but are not limited to cash, goods, services, discounts, rebates, travel tickets, accommodations, event invitations, or any item of value. Even if not intended to influence, the perception of impropriety can damage the integrity of the institution.

Permissible Exceptions:

• Unsolicited gifts of nominal or insignificant value, such as promotional items (e.g., pens, calendars), or tokens customary to cultural or academic traditions, may be accepted provided they do not exceed the threshold set by university regulations.
• Gifts received as part of official university ceremonies, conferences, or reciprocal institutional visits must be recorded and reported to the Office of the University President.

Hospitality Guidelines:

• Hospitality such as modest meals or refreshments during official engagements may be accepted if it is customary, infrequent, and not extravagant.
• Invitations to events or travel sponsored by third parties must receive prior written approval from the University President or designated authority and be evaluated for relevance and appropriateness.
• All gifts and hospitality offered or received in a personal or official capacity must be disclosed in a Gifts and Hospitality Register maintained by the Committee on Anti-Red Tape. Failure to report such instances shall be considered a violation of this policy.

VI. ROLES AND RESPONSIBILITIES

The implementation of this Policy is a shared responsibility across all levels of SLSU’s governance structure. Each unit, officer, and employee plays a vital role in ensuring a culture of integrity and in preventing corrupt practices.

A. Board of Regents

• Endorse and adopt the Anti-Bribery and Anti-Corruption Policy.
• Ensure strategic oversight and establish an institutional tone of ethical leadership.
• Approve internal controls and risk management frameworks to mitigate bribery and corruption risks.

B. Office of the University President

• Ensure policy integration into the University’s governance, operations, and planning systems.
• Provide overall leadership, allocate resources for training and enforcement, and ensure continuous improvement.
• Designate Committee on Anti-Red Tape as the focal unit to lead policy implementation.

C. Committee on Anti-Red Tape

• Oversee the day-to-day implementation of the Policy.
• Maintain records of reports, investigations, and outcomes.
• Conduct regular risk assessments, audits, and compliance checks.
• Serve as the focal point for receiving complaints, disclosures, and inquiries.

D. Internal Audit Unit

• Evaluate the effectiveness of internal controls and recommend corrective actions.
• Conduct periodic and surprise audits of procurement, finance, and administrative functions.

E. Human Resource Management Office (HRMO)

• Integrate anti-corruption principles into recruitment, induction, and performance appraisal systems.
• Administer mandatory training and ethics seminars.

F. Employees, Faculty, and Staff

• Be fully aware of, and compliant with, the Policy.
• Disclose conflicts of interest and gifts received.
• Report suspected violations promptly.

G. Students and Student Leaders

• Abide by the principles of the Policy in all dealings, especially in student government, scholarships, and organizational fund use.

VII. WHISTLEBLOWER PROTECTION AND REPORTING MECHANISM

SLSU strongly encourages employees, students, and stakeholders to report any suspected acts of bribery, fraud, or corruption. Whistleblowers are vital to the enforcement of this Policy and are assured of protection against retaliation, harassment, or discrimination.

Reporting Channels:

• Confidential reports may be submitted through the SLSU Committee on Anti Red Tape or the Office of the President.
• A dedicated email address will be provided to facilitate secure reporting.

Scope of Reports:

• Offers or solicitations of bribes
• Financial irregularities and fraudulent contracts
• Undue influence in hiring, procurement, grading, or accreditation
• Use of fixers or agents for illegal facilitation

Protection Measures:

• Identities of whistleblowers will be kept confidential unless disclosure is required by law or with written consent.
• Retaliatory acts such as dismissal, demotion, intimidation, or blacklisting are prohibited and punishable by appropriate sanctions.

All reports will be subject to preliminary assessment, investigation, and appropriate follow-up. Where necessary, cases may be referred to external oversight bodies such as the Civil Service Commission (CSC), Commission on Audit (COA), or Office of the Ombudsman.

VIII. COMPLIANCE AND MONITORING

SLSU is committed to rigorous monitoring and enforcement mechanisms to ensure the effectiveness of this Policy. Compliance is integral to both day-to-day operations and long-term institutional planning.

Monitoring Measures:

• Establishment of a university-wide compliance matrix to evaluate adherence.
• Regular internal audits and spot-checks conducted by the Internal Audit Unit.
• Maintenance of logs for Gifts and Hospitality, Conflict of Interest Declarations, and SALNs.
• Conduct of annual corruption risk assessments in high-exposure units such as procurement, admissions, and human resources.

Performance Indicators:

• Number of reported and resolved cases
• Policy violations and disciplinary actions taken
• Training participation rates
• External audit findings related to ethics and compliance

Compliance outcomes shall be reported quarterly to the University President and annually to the Board of Regents. Findings shall guide policy updates and strategic planning.

IX. SANCTIONS AND PENALTIES

Violations of this Policy shall be subject to administrative, civil, and criminal penalties, in accordance with university rules and Philippine laws, including RA 3019, RA 6713, and the Revised Penal Code.

Administrative Sanctions:

• Reprimand, suspension, or dismissal from service
• Revocation of scholarships, awards, or grants
• Blacklisting of contractors, suppliers, or external partners

Civil Actions:

• Recovery of ill-gotten gains or misappropriated funds
• Restitution of financial losses incurred by the university

Criminal Penalties:

• Referral of cases to the Office of the Ombudsman or Department of Justice for prosecution
• Imprisonment, fines, and disqualification from public office under applicable laws

The imposition of penalties shall follow due process, including formal investigation, right to be heard, and review by appropriate disciplinary bodies.

X. TRAINING AND AWARENESS

Education and awareness are critical to embedding a culture of integrity across the University. SLSU shall ensure that all members of the university community understand their responsibilities and the implications of engaging in corrupt practices.

Training Programs:

• Mandatory orientation on anti-bribery and corruption policy for all new employees and faculty members
• Annual refresher training courses for all personnel
• Specialized workshops for high-risk departments (procurement, finance, admissions, HR)

Communication and Advocacy:

• Dissemination of the Policy through the SLSU website, student portals, bulletin boards, and official handbooks
• Integration of ethics and anti-corruption modules into the General Education curriculum
• Celebration of "Anti-Corruption Month" with seminars, contests, and information campaigns

Evaluation of Training Effectiveness:

• Pre- and post-training assessments
• Feedback surveys and impact evaluation reports
• Inclusion of compliance knowledge in staff performance evaluations

XI. POLICY REVIEW

This policy shall be reviewed and updated annually or as may be necessary to reflect changes in the law or organizational structure.