University of Helsinki anti-corruption policy

1. Background and purpose

The purpose of the University of Helsinki’s anti-corruption policy is to prevent and help identify bribery and corruption. The University of Helsinki does not tolerate corruption (the giving or receiving of bribes) in any form.

Chapter 16 of the Criminal Code of Finland (No 39/1889) contains provisions on bribery which criminalise the acceptance and offering of gifts or other benefits in certain conditions. The nature or value of the gift or benefit is not defined in the said provisions.

Bribery means the giving or acceptance of any gift, loan, payment, fee or benefit if its purpose is to induce dishonest or illegal behaviour or a breach of trust in the University’s activities. The abuse of power or position in pursuit of personal benefit is also considered bribery. Members of the University community must not pursue any personal benefit by using their position or the University’s property, expertise or business opportunities. Representatives of the University must avoid business transactions or situations with associates that may cause a conflict of interest between the University and personal interests.

These guidelines apply to all staff of the University of Helsinki and the companies in the University of Helsinki Group as well as to all situations, including those in which members of the University community are offered a benefit as private individuals, but their actions are de facto based on their position at the University or in one of its subsidiary companies.

2. Guidelines

Regular gifts and common courtesy and hospitality are accepted as part of normal collaboration and interaction with associates, partners and service providers. Acceptable gifts or courtesy may include benefits that

  • Are given or received openly, without obligation and/or expectation of reciprocation
  • Can be accepted by the company’s associates and held up to public scrutiny
  • Are legal and reasonable in monetary terms
  • Are given or received irregularly (excl. annual Christmas gifts)

In addition, the recipient’s ethical guidelines for the prevention of corruption must be taken into account.

Benefits must not be given or accepted if

  • They are not considered common and reasonable practice
  • They give rise to suspicion of the motives of the giver or recipient
  • They give rise to suspicion of the arrangement’s impact on the results of the collaboration or on decision-making
  • They give rise to suspicion that the matter could attract unfavourable publicity to the University
  • The benefit could affect or appears to affect either party’s independence or impartiality
  • The benefit is in the form of cash or a gift card, excluding gift cards which can be used only for the purpose defined by the giver, entitle the recipient to a single service provider’s selection of pre-determined content and value, and cannot be directly exchanged for money

Special attention and caution are required if a collaboration or procurement agreement is currently being prepared.

2.1. Cultural, sports and entertainment events as well as excursions

The University’s instructions for travel apply to travel opportunities offered to members of the University community. The host of the event must participate in it.University staff may also accept tickets to events as well as meals and refreshments. The acceptability of such events and travel will be assessed with reference to the principles outlined in section 2 above.

2.2. Additional guidelines on hospitality extended to authorities

Members of the University community must ensure that any benefits they offer to authorities are in line with the Government instructions for authorities concerning the acceptance of hospitality. The Government instructions stipulate the following:

  • Authorities must take particular care to ensure that their actions remain impartial and also appear impartial to associates and the public.
  • As a rule, authorities must take a restrictive approach to the acceptance of hospitality.
  • The acceptance of hospitality is forbidden in certain situations, such as when performing supervisory or inspection activities, preparing procurement decisions or making a decision on the provision of services.

2.3. Additional guidelines on charity, sponsorshipand political support

Members of the University community must ensure that their support for a charity or sponsorship is not used to hide corruption. The University and its subsidiary companies do not provide direct or indirect support to political parties, organisations or individual politicians.

The University must follow equivalent principles when receiving donations in support of its activities, i.e., a donation cannot constitute hidden corruption.

3. Assessment

University staff who represent the University or give or receive benefits must carefully assess the grounds and necessity of such benefits. University staff who give or receive benefits hold the primary responsibility for ensuring that the benefits comply with the criteria for acceptability outlined in this policy.

If necessary, this assessment can be performed with the supervisor. In unclear cases, the appropriateness of the benefit must be discussed with the director of administration.

The assessment must take into account the individual circumstances, the nature and purpose of the benefit, and the status of the giver and recipient as well as their connections to collaboration.

The University shares features with both private and public organisations. The University assesses common and reasonable business practice from the perspective of a company engaged in business operations.Because the University also has a role in public administration, it must take particular care to assess which business practices are suitable.

In addition, the University’s image, the risks to its reputation and the value of the benefit or gift in the eyes of third parties must always be taken into account. Confidence in the University is likely to be compromised if the giving or acceptance of a financial benefit or gift may affect business operations in the eyes of third parties: “It is what it appears to be.”

The director of administration or the legal affairs unit must immediately report any violations of the anti-corruption policy to the rector, and notify the Board and its audit committee of such violations as soon as possible.

4. ResponsibiliTies

The University of Helsinki is committed to the practical implementation of the anti-corruption policy.

The Board has approved this policy and holds the overall responsibility for compliance with them at the University. The rector is responsible for the coherent implementation of the policy based on a clearly defined authority. The Board, the rector and other members of senior management must be active and visible examples in applying this policy to all their activities.

All members of the University community and staff of the University of Helsinki Group must take responsibility for following the policy.

5. PARTNERS AS WELL AS SUBSIDIARY AND JOINT COMPANIES

The University of Helsinki and its subsidiaries must apply the anti-corruption policy in all their business relations and operations. We expect our partners to commit to equivalent responsible practices. This is the basic premise for concluding and maintaining business relations.

We ensure that our subsidiary and joint companies, which the partner in question can legally influence, adopt the anti-corruption policy and otherwise comply with good business practice.