What the Policy provides
- Who is covered. Council members, executive leadership, academic and administrative staff, contractors, consultants and third parties acting for the University. It also applies to students, vendors, donors and partners who deal with the University on funds, procurement, recruitment, admissions, assessment or research, on and off campus and online.
- Prohibited conduct. Active and passive bribery, facilitation payments, misuse of position or University assets, influencing recruitment, admissions or grading through personal ties, falsifying records, colluding with vendors, misappropriating funds, and submitting false or inflated claims.
- Conflicts of interest. Staff involved in financial or recruitment decisions make an annual declaration of interest, declare any conflict as it arises and step aside from the decision. The recusal is recorded.
- Gifts and hospitality. Gifts above nominal value are surrendered or recorded in an Official Gift Register. Cash, vouchers, loans, vendor per diems, personal discounts and personal travel benefits are prohibited, and staff may not solicit benefits. Modest, transparent hospitality with a clear University purpose is allowed.
- Public finance and procurement. Competitive bidding is the default. Every stage is documented for audit, emergency or sole-source procurement needs the Financial Controller’s documented approval, and procurement may not be split to avoid thresholds.
- Ethics and Compliance Committee. A committee chaired by the senior officer for Administration and Finance, with the Financial Controller, Head of Internal Audit, Head of Human Resources, Head of Finance and Legal Counsel, reviews high-risk procurement, investigates breaches and recommends referrals to the Anti-Corruption Commission.
- Employees must report suspected corruption through Internal Audit, the Committee, the Vice Chancellor, supervisors, Human Resources or Legal Counsel. Good-faith reporters are protected under the Whistleblower Protection Act (Law No. 16/2019), which also requires institutions to have internal reporting systems. Where these internal channels fail, or the concern involves those responsible for them, staff may use the alternative route of the University’s Whistleblower Protection Committee and Whistleblower Protection Officer, as the Human Rights Commission’s guidelines on internal whistleblowing mechanisms require. Under those guidelines, complaints are registered and checked for admissibility within three days, investigations conclude within 21 days (extendable by 30 days with notice to the complainant), and the identity of the whistleblower is kept confidential.
- The person accused has a reasonable chance to respond. Sanctions range from a written warning to termination, recovery of losses, cancellation of contracts, exclusion from procurement, and referral to the Anti-Corruption Commission or the police.
- Internal Audit monitors compliance, secure records are kept, training is required and the Policy is reviewed at least every three years.
Protection for people who raise concerns
This route is for corruption and irregularities. Employment disputes, discrimination and harassment are handled through Human Resources and the relevant committees and, if unresolved, the Employment Tribunal. The University has appointed a Whistleblower Protection Committee and Officer, and it follows the Human Rights Commission’s Guideline on Establishing Internal Whistleblowing Mechanisms in Government Institutions, and on Processing and Investigating Disclosures, issued under the Whistleblower Protection Act (Law No. 16/2019) by the Whistleblower Protection Unit. Under the Guideline:
- Ways to report. Disclosures may be made in person, by letter, telephone, text message, email, audio or video, on a prescribed form or through the institution’s website, and anonymously.
- A person who discloses wrongdoing in good faith, and anyone who helps an investigation, is protected from dismissal, transfer, discipline and criminal action, and may seek compensation or apply to the Employment Tribunal or a court. Identity is kept confidential.
- Prompt handling. The officer registers each disclosure, the committee meets within three days to decide whether it falls within its remit, urgent matters are acted on within three days, and investigations are completed within 21 days, with an extension of up to 30 days on notice.
- Impartial handling. Staff with a conflict of interest, including family or commercial ties, step aside from a case. Suspected corruption is reported to the Anti-Corruption Commission and criminal matters are referred to the competent authority.
- Awareness and openness. Staff are informed of the mechanism, training is held at least twice a year, and investigation reports are published on the institution’s website with identifying details removed where needed.
Our practice before the 2026 policy
Maldives National University is a public university established by the Maldives National University Act (Law No. 3/2011). Its governance has been conducted in compliance with the anti-corruption and public finance rules that apply to the public sector: the Prevention and Prohibition of Corruption Act (Act No. 2/2000), the Penal Code (Act No. 9/2014), the Public Finance Act (Act No. 3/2006) and its Regulation. The University has followed the Whistleblower Protection Act since it came into force in October 2019, and has appointed a Whistleblower Protection Committee and Officer under the Human Rights Commission’s guidelines, together with the Human Rights Commission’s Whistleblower Protection Unit regulation (Regulation 5/R/2020, amended by Regulation 80/R/2021), and its procurement follows the MNU Procurement Policy in conjunction with the Public Finance Act and the government procurement regulation. Staff have been bound by the University’s Ethics Policy, the Code of Conduct for Academic Staff (approved 10 July 2016, effective 23 April 2018) and the Conflict/Non-conflict of Interest Declaration Form.
Legal framework
The Prevention and Prohibition of Corruption Act (Act No. 2/2000), the Penal Code (Act No. 9/2014), the Public Finance Act (Act No. 3/2006), the Public Finance Regulation and its procurement chapter, and the Whistleblower Protection Act (Law No. 16/2019) with the Whistleblower Protection Unit regulation and the Guideline on internal whistleblowing mechanisms. The Civil Service Commission’s legislation page lists the rules for public servants.
Related Pages and Policies
Sources
Approved by the University Council; in effect from 28 September 2026.
