Corruption Prevention Officer of the University of Münster
Ralph Harnacke
Robert-Koch-Straße 40
Tel.: +49 251 83-24743
antikorruption@uni-muenster.de
In order to effectively prevent corruption, employees, business partners and third parties need someone they can speak with about concerns or suspicions they have regarding wrong-doing – confidentially, outside of official channels and anonymously, if necessary.
The Compliance Office handles such matters on a general basis. With respect to the area of corruption, the Corruption Prevention Officer (BfK) is also available to provide assistance and advice.
Should the Compliance Office receive information related to corruption, it forwards this information to the BfK. Conversely, all cases reported to the BfK, which have undergone an initial plausibility assessment, are reported to the Compliance Office.
If the BfK is prevented from carrying out his/her duties for whatever reason, the Compliance Office assumes these in his/her stead.
The BfK is appointed by the Rectorate normally for a term of two years. Prior dismissal is only possible if the BfK can no longer exercise his/her duties in the long-term or is prevented from doing so on a permanent basis.
In order to carry out these duties, the BfK is granted unrestricted rights to information.
The BfK receives tips (confidentially, if desired) concerning possible cases of corruption, investigates the allegations and then takes further steps in agreement with the University management, provided that a member of the University management is not the accused party. If so, after reviewing the allegations, the BfK forwards the matter to the Compliance Office.
The BfK also decides whether to involve or share information with other authorities in coordination with the University management.
During and after his/her term in office, the BfK is subject to secrecy regarding any information about the personal affairs of the University staff. This does not apply to interactions with the University management and persons conducting civil-service or labour law-related investigations based on facts supporting the allegations of corruption. Moreover, the BfK is not permitted to participate in disciplinary procedures.
The BfK is obliged to treat all files containing personal information created during his/her term of office with absolute confidentiality. Personal data is stored for as long as necessary to provide clarification and conduct a final assessment of the matter, or to meet the legal obligations of the University of Münster, or for other reasons prescribed by law.
Personal data, which clearly has no relevance to the suspicion in question, is not collected or is immediately deleted if such information is collected unintentionally.
The BfK is not only a contact for matters of corruption prevention. He/she is also responsibile for the following tasks:
- informing, heightening awareness and offering employee training on matters of corruption prevention (see the University’s continuing education programme),
- documenting and implementing legal regulations related to corruption prevention, including monitoring rotation and the dual control principle,
- conducting risk analyses and producing the risk atlas, exercising the right to make recommendations to the Rectorate on matters related to corruption prevention matters.
The BfK is free to exercise his/her duties in his/her area of responsibility and competence as he/she sees fit. The BfK may conduct reviews or random samples unannounced in corruption-prone areas. If requested, all employees and offices are obliged to promptly disclose information to the BfK, insofar as the employees/offices are not explicitly bound to secrecy by law with respect to the information in question.
The activities of the BfK are supported by the Internal Audit department, provided that such support is deemed necessary and appropriate by the BfK or the University management.
The BfK is obliged to submit a report of his/her activities to the Rectorate once a year.