Regulatory Compliance & Anti-Corruption Governance: Public Principles on Preventing Corruption and Bribery at TSUULL

TSUULL is committed to fostering a culture of integrity, transparency, and accountability. The University’s Anti-Corruption Regulations are fully aligned with the Law on Combating Corruption of the Republic of Uzbekistan and establish clear standards for ethical conduct, prevention of corruption, risk management, and reporting mechanisms. The Regulations are guided by fundamental principles derived from national law and international best practices, including legality, priority of rights, openness and transparency, systemic prevention, state–civil society cooperation, priority of prevention, and inevitability of responsibility. Legality ensures full compliance with the Constitution, the Law on Combating Corruption, and related legislation, prohibiting bribery, fraud, or misuse of authority. Priority of rights safeguards the legal interests, rights, and dignity of all University community members, ensuring fairness and due process in investigations. 

Related articles:

TSUULL ANTI-CORRUPTION POLICY (2023)
TSUULL Policy on Anti-Corruption Compliance and Governance (2025)

Prevention, Risk Management, and Internal Controls
3.1 Legal Risk Assessment
3.1.1 Department heads and heads of organizational units must conduct regular, systematic risk assessments of all activities and operations that may create opportunities for corruption, bribery, or unethical behavior. These areas include, but are not limited to, the acceptance or offering of gifts, interactions with third-party representatives, procurement processes, financial transactions, contracts, sponsorships, partnerships, and media relations.

3.1.2 Risk assessments must identify both inherent and emerging risks, evaluate the likelihood and potential impact of corruption-related incidents, and propose appropriate mitigation measures.

3.1.3 All findings from risk assessments, along with mitigation strategies, must be documented, securely stored, and made available to the University’s Compliance-Control Department for review and monitoring.

3.1.4 Risk assessments should be updated at least annually or whenever significant operational changes occur, including the introduction of new programs, external partnerships, or funding mechanisms.

3.3 Conflict of Interest Management
3.3.1 All staff, administrative officers, faculty members, and key student leaders (e.g., student council members) are required to declare any potential or actual conflicts of interest on an annual basis or immediately upon becoming aware of a conflict.

3.3.2 Declarations are reviewed by the University Ethics or Compliance department, which recommends appropriate actions, including recusal from decision-making, reassignment of responsibilities, or other mitigating measures.

3.3.3 Non-disclosure of conflicts, failure to comply with mitigation measures, or intentional violation of conflict-of-interest rules will result in disciplinary action in accordance with national legislation and University regulations.

3.3.4 Conflict-of-interest policies apply to financial, professional, familial, or personal relationships that could influence impartial decision-making in academic, financial, or administrative matters.

3.4 Preventive Programs & Education
3.4.1 The University develops and implements comprehensive Anti-Corruption Education Programs for all staff and students. These programs include workshops, training sessions, webinars, seminars, and awareness campaigns designed to strengthen understanding of anti-corruption principles, applicable laws, and reporting obligations.

3.4.2 Relevant academic curricula integrate anti-corruption topics, particularly in departments such as law, public administration, management, and finance, to ensure students gain practical knowledge on ethics and compliance.

3.4.3 Preventive programs also include distribution of guidance materials, brochures, and e-learning modules to ensure that University members are aware of their responsibilities under these Regulations and national legislation.

3.4.4 The University monitors the effectiveness of preventive programs through surveys, feedback mechanisms, and regular assessment of compliance levels.

Reporting, Investigation, and Protection

4.1 Reporting Mechanisms
4.1.1 TSUULL provides secure, reliable, and confidential channels for reporting suspected corruption, bribery, or other unethical activities.
4.1.2 All reports should be submitted primarily to the University’s Anti-Corruption Compliance-Control Department, which is responsible for receiving, recording, assessing, and coordinating investigations of reported cases.

4.1.3 Reporting channels include:

• •  Direct communication (in person, phone, or email) with the Compliance-Control Department;
• •  Secure, University-approved online portals for confidential or anonymous reporting;
• •  Contact with the University Board of Trustees in cases where the Compliance-Control Department is unavailable.

4.1.4 Reports are reviewed promptly, and preliminary assessments determine whether further investigation is required. Serious or high-risk cases are escalated to national anti-corruption authorities in accordance with the Law on Combating Corruption of the Republic of Uzbekistan.

4.1.5 All members of the University community, including staff, students, and third-party agents, are encouraged to report suspicions in good faith. Reports made maliciously or in bad faith may result in disciplinary action.

4.2 Whistleblower Protection
4.2.1 Individuals who report corruption, bribery, or other misconduct, as well as their close relatives, are protected from any form of retaliation, harassment, or discrimination.

4.2.2 TSUULL ensures that the identity of whistleblowers remains confidential, except as required by law or court order.

4.2.3 The University provides support to whistleblowers, including legal consultation, psychological counseling, and, if necessary, temporary adjustments to work or study arrangements to ensure safety and well-being.

4.2.4 Retaliation against whistleblowers is strictly prohibited, and any violation will result in disciplinary action or referral to law enforcement, consistent with national legislation.

4.3 Investigation & Sanctions
4.3.1 The Compliance-Control Department coordinates internal investigations and, when necessary, cooperates with national law enforcement or prosecutorial authorities for cases involving significant corruption risks.

4.3.2 Investigations are conducted in a fair, impartial, and timely manner, preserving confidentiality and protecting the rights of all parties involved.

4.3.3 Sanctions for confirmed cases of corruption or bribery may include:

• •  Disciplinary actions ranging from warnings to termination of employment or expulsion of students;

4.3.4 The University maintains records of all investigations and actions taken to ensure accountability and facilitate reporting to national anti-corruption agencies as required.

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