BAC EDUCATION GROUP

ETHICS POLICY

Brickfields Asia College | IACT College | Reliance College | Veritas University College | UNIMY

(Ethics, Integrity and Responsible Conduct Policy)

Document Reference	BAC-EIRC-2025-001)
Version	1.0
Effective Date	1 July 2025 (v1.0)
Approved By	Board of Directors, BAC Education Group
Review Cycle	Every Two (2) Years
Classification	Official / Internal

DOCUMENT CONTROL

Version	Date	Description	Prepared By	Approved By
1.0	01/07/2025	Human Rights & Inclusion, AI Ethics expansion, Ethics KPIs & Monitoring, Mandatory Training, ESG Ethics linkage, Research Integrity expansion, External Reporting.	Group Legal; Group Quality Assurance Office	Board of Directors

DOCUMENT DISTRIBUTION

Copy No.	Institution	Copy Holder	Date Issued
1	BAC Education Group (Group Level)	Group Chief Executive Officer	01/07/2025
2	Brickfields Asia College	Principal / Chief Executive	01/07/2025
3	IACT College	Principal / Chief Executive	01/07/2025
4	Reliance College	Principal / Chief Executive	01/07/2025
5	Veritas University College	Vice Chancellor / President	01/07/2025
6	UNIMY	Vice Chancellor / President	01/07/2025

PART A: PRELIMINARY

1. Preamble and Introduction
2. Vision, Mission and Core Values
3. Human Rights, Equity and Inclusion
4. Scope and Application
5. Definitions
6. Legislative and Regulatory Framework

PART B: ETHICAL STANDARDS AND OBLIGATIONS

7. Code of Ethics for Academic Staff
8. Code of Ethics for Non-Academic Staff
9. Code of Ethics for Students
10. Code of Ethics for Management and Leadership
11. Academic Integrity
12. Research Ethics and Integrity
13. Conflict of Interest
14. AI Ethics and Responsible Technology

PART C: GOVERNANCE, REPORTING AND ENFORCEMENT

15. Ethics Governance Structure
16. Reporting Mechanism and Whistleblowing
17. Investigation Procedures
18. Disciplinary Action and Sanctions
19. Protection Against Victimisation
20. Ethics Performance Monitoring and KPIs
21. Mandatory Ethics Training and Awareness
22. Annual Ethics Report and External Disclosure

PART D: SPECIFIC POLICIES

23. Anti-Bribery and Anti-Corruption
24. Sexual Harassment and Dignity at Work
25. Data Privacy and Confidentiality
26. Use of Technology and Social Media
27. Sustainability and ESG Ethics

PART E: FORMS AND SOPs

SOP 1: Ethics Complaint / Reporting Procedure
SOP 2: Conflict of Interest Disclosure Procedure
SOP 3: Academic Integrity Investigation Procedure
SOP 4: Ethics Training Delivery and Tracking Procedure
FORM 1: Ethics Complaint / Reporting Form (ECF-001)
FORM 2: Conflict of Interest Declaration Form (CIDF-002)
FORM 3: Academic Integrity Incident Report (AIIR-003)
FORM 4: Annual Ethics Compliance Declaration (AECD-004)
FORM 5: Research Ethics Approval Application (REAA-005)
FORM 6: Ethics & Integrity Training Completion Record (ETCR-006)
FORM 7: Annual Ethics KPI & Performance Report (AEKR-007)

PART A: PRELIMINARY

1. PREAMBLE AND INTRODUCTION

BAC Education Group (the ‘Group’) comprises five distinguished higher education institutions: Brickfields Asia College, IACT College, Reliance College, Veritas University College, and UNIMY (the University of Malaysia International Youth). Together, these institutions serve thousands of students and employ hundreds of staff across Malaysia.

The Group is committed to upholding the highest standards of ethical conduct, academic integrity, professional responsibility and good governance in all its activities. This Ethics, Integrity and Responsible Conduct Policy (‘Policy’) establishes a comprehensive framework of ethical standards, obligations, performance measures and processes that apply across the Group.

This Policy is grounded in and consistent with:

The National Education Philosophy (Falsafah Pendidikan Kebangsaan) of Malaysia
The Malaysian Teachers’ Code of Ethics (Tatasusila Profesyen Keguruan)
The Malaysian Anti-Corruption Commission Act 2009 (MACC Act)
The Malaysian Code on Corporate Governance (MCCG)
The Private Higher Educational Institutions Act 1996 (PHEIA 1996) and its amendments
The Malaysian Qualifications Agency Act 2007 (MQA Act)
The Personal Data Protection Act 2010 (PDPA)
The Employment Act 1955 (and its amendments)
The Federal Constitution of Malaysia, Article 8 (Equality before the law)
The Persons with Disabilities Act 2008 (Act 685)
Malaysia’s National AI Roadmap and AI Governance and Ethics (AIGE) Guidelines (MOSTI, 2024), as further implemented in the Group AI Governance Policy
QS Stars and QS World University Rankings methodology, insofar as it informs institutional good-practice benchmarks for ethics, integrity and sustainability

This Policy applies to all private colleges and private universities within the Group and is designed to fulfil the ethical standards required by the Ministry of Higher Education Malaysia (MOHE) and the Malaysian Qualifications Agency (MQA), and to support institutional benchmarking against international quality frameworks such as QS Stars.

2. VISION, MISSION AND CORE ETHICAL VALUES

2.1 Vision

To be a leading education group in Malaysia that is recognised for excellence, integrity, and positive social impact.

2.2 Mission

To provide quality education in a safe, ethical, inclusive, and professionally managed environment, nurturing individuals who are competent, responsible and of strong moral character, and to measure and report on our ethical performance with the same rigour we apply to academic performance.

2.3 Core Ethical Values (BAC GROUP-ETHICS)

Value	Description
Amanah (Trustworthiness)	Honesty and reliability in all dealings with students, staff, regulators and the public.
Integriti (Integrity)	Adherence to moral and ethical principles; soundness of character.
Tanggungjawab (Responsibility)	Accountability for one’s actions and decisions.
Hormat (Respect)	Treating all individuals with dignity and fairness regardless of background.
Kecemerlangan (Excellence)	Commitment to the highest standards of academic and professional quality.
Keadilan (Justice)	Fair, impartial and equitable treatment of all stakeholders.
Inovasi (Innovation)	Encouraging ethical creativity and continuous improvement.
Patriotisme (Patriotism)	Contributing positively to the development of Malaysia and its society.

3. HUMAN RIGHTS, EQUITY AND INCLUSION

3.1 Policy Statement

BAC Education Group is committed to upholding the fundamental human rights and dignity of every student, staff member and stakeholder, in accordance with the Federal Constitution of Malaysia, the Persons with Disabilities Act 2008 (Act 685), and international human rights instruments to which Malaysia is a party. The Group affirms that respect for human rights, equity and inclusion is foundational to its ethical culture and is not merely incidental to its other obligations under this Policy.

3.2 Commitments

The Group is committed to:

Equality of Opportunity — ensuring that access to education, employment and advancement within the Group is based on merit, free from arbitrary or unlawful discrimination.
Non-Discrimination — prohibiting discrimination on the grounds of race, religion, gender, age, disability, nationality, socio-economic background, marital or parental status, or any other status protected by Malaysian law.
Accessibility — ensuring that campuses, facilities, digital platforms and learning materials are accessible to persons with disabilities, consistent with the Persons with Disabilities Act 2008 and the Group’s ICT & e-Learning Policy (accessibility features).
Inclusion of Persons with Disabilities — providing reasonable accommodations in admissions, teaching, assessment and employment, and maintaining a Disability Support Officer or equivalent function at each Institution.
Gender Equity — promoting equal opportunity and treatment for all genders in admissions, employment, remuneration, and representation in leadership and governance roles.
Respect for Cultural and Religious Diversity — recognising and respecting Malaysia’s multicultural and multi-religious society, and fostering a campus culture in which all students and staff can practise their faith and culture without fear of discrimination or harassment, subject to applicable law and institutional policy.

3.3 Implementation

Each Institution shall designate a Human Rights, Equity and Inclusion focal point (which may be a role held by an existing officer, such as the Head of Student Affairs or HR) responsible for monitoring compliance with this Section.
Complaints relating to discrimination, lack of accessibility, or breach of this Section may be lodged using Form ECF-001 (Section 16) and shall be handled under the same investigation and disciplinary framework as other ethics complaints (Sections 17-19).
Human Rights, Equity and Inclusion indicators shall form part of the Ethics Performance Monitoring framework under Section 20.

4. SCOPE AND APPLICATION

This Policy applies, without exception, to:

All permanent, contract, part-time and adjunct academic staff
All non-academic, administrative and support staff
All management and leadership personnel including Board members and Council members
All full-time, part-time and online students enrolled in any programme
All third-party contractors, vendors, consultants and agents acting on behalf of the Group
All alumni in their dealings with the institution

This Policy applies at all Group campuses, off-campus activities, online/virtual environments, research settings, and any other location where institutional activities are conducted.

Where specific institutions have additional requirements under their respective charters, instruments of incorporation, or regulatory approvals, those requirements shall be read together with this Policy. In the event of conflict, the stricter standard shall prevail.

5. DEFINITIONS

Term	Definition
Academic Integrity	The commitment to the fundamental values of honesty, trust, fairness, respect, responsibility and courage in all academic work.
Academic Staff	Lecturers, tutors, professors, associate professors, senior lecturers and all persons engaged in teaching and/or research.
AIGE	AI Governance and Ethics Guidelines issued by Malaysia’s Ministry of Science, Technology and Innovation (MOSTI), 2024.
Conflict of Interest	A situation where a personal interest may improperly influence the performance of official duties.
COPE	Committee on Publication Ethics — an international body providing guidance on research and publication integrity.
Disability Support Officer	A designated officer at each Institution responsible for coordinating reasonable accommodations for students and staff with disabilities.
ESG	Environmental, Social and Governance — a framework for evaluating an organisation’s sustainability and ethical impact (see Section 27 and the Group’s Sustainable Funding & Donations Policy and Sustainable Investing Policy).
Ethics Committee	The committee established at Group and institutional levels responsible for administering this Policy.
Group	BAC Education Group, comprising Brickfields Asia College, IACT College, Reliance College, Veritas University College and UNIMY.
Group AI Governance Policy	The Group’s standalone policy governing the development, procurement and use of artificial intelligence, including the five-level Group AI Use Scale.
Institution	Any one of the colleges or universities within the Group.
KPI	Key Performance Indicator — a measurable value used by the Group to evaluate the effectiveness of its ethics, integrity and governance framework (see Section 20).
Management	The Board of Directors, Senate, Academic Board, Committees and senior officers responsible for governance and administration.
Misconduct	Any act or omission that contravenes the standards set out in this Policy or applicable law.
MOHE	Ministry of Higher Education Malaysia (Kementerian Pendidikan Tinggi).
MQA	Malaysian Qualifications Agency (Agensi Kelayakan Malaysia).
Open Science	A movement to make scientific research, data and dissemination accessible to all levels of society, including open access publication and open data sharing.
PHEIA	Private Higher Educational Institutions Act 1996.
Predatory Journal	A publication that charges authors a fee to publish, typically without legitimate editorial or peer-review services, exploiting the open-access model for profit.
SDG	Sustainable Development Goals — the 17 goals adopted by the United Nations as a shared blueprint for peace and prosperity for people and the planet by 2030.
Staff	Any person employed by the Group or any Institution, whether full-time, part-time, contract or temporary.

Student	Any person enrolled in any academic programme offered by any Institution within the Group.
Whistleblower	A person who reports in good faith a suspected breach of ethics or misconduct.

6. LEGISLATIVE AND REGULATORY FRAMEWORK

This Policy is anchored in the following Malaysian laws, regulations and guidelines:

Legislation / Guideline	Relevance to this Policy
Private Higher Educational Institutions Act 1996 (Act 555) & Amendments	Regulatory framework for private colleges and universities, including governance, staff conduct and student affairs.
Malaysian Qualifications Agency Act 2007 (Act 679)	Standards for academic quality, institutional accountability, programme conduct and ethical research.
Education Act 1996 (Act 550)	General education framework and obligations of educational institutions.
Employment Act 1955 (Act 265)	Employment terms, disciplinary procedures and employee rights.
Malaysian Anti-Corruption Commission Act 2009 (Act 694)	Anti-bribery and anti-corruption obligations for all persons.
Personal Data Protection Act 2010 (Act 709)	Protection of personal data of students, staff and third parties.
Whistleblower Protection Act 2010 (Act 711)	Protection for individuals reporting wrongdoing in good faith.
Communications and Multimedia Act 1998 (Act 588)	Ethical use of digital platforms and online communications.
National Education Philosophy 1988 (Falsafah Pendidikan Kebangsaan)	Foundational philosophy guiding the values and purpose of education in Malaysia.
Code of Ethics for the Teaching Profession (Tatasusila Profesyen Keguruan)	Ethical obligations of teachers and academic educators.
Malaysian Code on Corporate Governance 2021 (MCCG 2021)	Governance standards for organisations in Malaysia.
MQA Code of Practice for Programme Accreditation (COPPA 2.0)	Standards for academic integrity and institutional responsibility.
Federal Constitution of Malaysia, Article 8 (Equality)	Constitutional guarantee of equality before the law and protection from discrimination; underpins Section 3 (Human Rights, Equity and Inclusion).
Persons with Disabilities Act 2008 (Act 685)	Rights of persons with disabilities to access education, employment, and public facilities without discrimination; underpins Section 3.
AI Governance and Ethics (AIGE) Guidelines, MOSTI 2024	National framework for responsible, transparent and accountable AI use; underpins Section 14 (AI Ethics and Responsible Technology) and the Group AI Governance Policy.
COPE (Committee on Publication Ethics) Core Practices	International best-practice guidance on research and publication integrity, authorship, and handling of misconduct; underpins Section 12 (Research Ethics and Integrity).

PART B: ETHICAL STANDARDS AND OBLIGATIONS

7. CODE OF ETHICS FOR ACADEMIC STAFF

7.1 Responsibilities Toward Students

Every academic staff member shall:

Give foremost consideration to the welfare, safety, wellbeing and holistic development of every student in their care.
Direct their full professional effort to assist students in developing intellectually, emotionally, physically and morally.
Foster in students the values of honesty, integrity, respect for diversity, critical thinking and responsibility.
Act at all times with fairness and without discrimination on grounds of race, religion, gender, nationality, disability, socio-economic status or political affiliation.
Respect the confidentiality of student information and academic records.
Never exploit, abuse or misuse the teacher-student relationship for personal, financial or sexual gain.
Maintain appropriate professional boundaries with students at all times, including in digital and online interactions.
Make reasonable accommodations for students with disabilities or additional learning needs, in consultation with the Disability Support Officer, consistent with Section 3 of this Policy.

7.2 Responsibilities Toward the Profession

Every academic staff member shall:

Maintain and continuously improve their professional knowledge, skills and competencies.
Conduct themselves in a manner that upholds the dignity and prestige of the teaching profession.
Not engage in activities that bring the profession or the Institution into disrepute.
Acknowledge the intellectual contributions of others and avoid all forms of plagiarism.
Declare and manage conflicts of interest in accordance with Section 13 of this Policy.
Comply with all applicable professional codes issued by relevant professional bodies.
Complete mandatory ethics and integrity training in accordance with Section 21 of this Policy.

7.3 Responsibilities Toward Colleagues

Treat all colleagues with respect, professionalism and courtesy.
Refrain from harassment, bullying, discrimination or any behaviour that creates a hostile work environment.
Support the professional development of colleagues and juniors.
Not undermine the professional reputation of colleagues through malicious gossip, false allegations or sabotage.

7.4 Responsibilities Toward Parents, Community and Nation

Communicate honestly and respectfully with parents and guardians regarding student progress and welfare.
Uphold the values of the National Education Philosophy (Falsafah Pendidikan Kebangsaan).
Contribute positively to the community and to national development.
Avoid spreading teachings, materials or views that are subversive, seditious or harmful to national unity.

7.5 Assessment and Grading Ethics

Assess student work objectively, consistently and in accordance with the approved assessment criteria.
Not accept gifts, favours or inducements in connection with grading or assessment.
Declare any personal relationship with a student that could compromise objectivity in assessment.
Maintain the security and confidentiality of examination papers and assessment materials.
Where AI tools are used to support assessment design, marking, or feedback, comply with the principles set out in Section 14 (AI Ethics and Responsible Technology), including disclosure to students and maintenance of human oversight over final grading decisions.

8. CODE OF ETHICS FOR NON-ACADEMIC STAFF

8.1 Core Obligations

All non-academic and support staff shall:

Perform their duties diligently, professionally and with integrity.
Treat all students, staff and visitors with courtesy, fairness and respect.
Maintain strict confidentiality regarding institutional and personal information accessed in the course of their duties.
Use institutional resources, including IT systems, only for authorised purposes.
Not solicit or accept bribes, gifts or corrupt gratification from any party.
Disclose and manage all conflicts of interest in accordance with this Policy.
Report suspected misconduct, fraud or unethical behaviour through the appropriate channels.
Complete mandatory ethics and integrity training in accordance with Section 21 of this Policy.

8.2 Admissions and Enrolment Staff

Staff involved in student admissions shall, additionally:

Ensure all admissions decisions are based solely on merit, prescribed requirements and institutional policy.
Never accept payment, gifts or favours in exchange for preferential treatment in admissions.
Provide accurate and truthful information to prospective students and parents.
Respect the privacy of applicant information.
Ensure that admissions criteria and processes do not directly or indirectly discriminate against applicants on any ground prohibited under Section 3 of this Policy, including disability status.

8.3 Finance and Procurement Staff

Staff involved in financial management and procurement shall:

Comply with all applicable financial regulations and institutional financial policies.
Never falsify financial records, invoices, receipts or reports.
Ensure procurement processes are transparent, competitive and free from favouritism.
Declare all interests in vendors, suppliers or contractors.
Apply the responsible procurement criteria set out in Section 27 (Sustainability and ESG Ethics) when evaluating suppliers and contractors.

9. CODE OF ETHICS FOR STUDENTS

9.1 Academic Conduct

All students enrolled at any Institution within the Group shall:

Conduct all academic work honestly and with integrity — free from plagiarism, cheating, fabrication, falsification and collusion.
Submit only their own work, unless collaboration is expressly permitted by the academic staff.
Properly cite and acknowledge all sources used in academic work.
Not impersonate another student or allow another to impersonate them in any academic activity.
Not access, tamper with or share confidential examination or assessment materials.
Complete the mandatory student ethics orientation and academic integrity certification described in Section 21 prior to commencing or continuing their studies, as applicable.

9.2 Behaviour and Conduct

Treat all members of the institutional community — staff, fellow students and visitors — with dignity and respect.
Refrain from any form of harassment, bullying, intimidation, discrimination or violence.
Behave responsibly both on and off campus, including in online and social media environments.
Not engage in activities that endanger themselves or others, or that bring the Institution into disrepute.
Comply with all institutional regulations, codes and policies.

9.3 Use of Institutional Resources

Use institutional facilities, equipment, IT systems and library resources responsibly and only for authorised purposes.
Not damage, destroy or misappropriate institutional property.
Respect the intellectual property rights of others and of the Institution.

9.4 Community Responsibilities

Participate constructively in student activities and community initiatives.
Report unethical behaviour by peers through the appropriate channels.
Act as ambassadors of the Institution in the wider community.
Are encouraged to participate in the Group’s sustainability, community engagement and SDG-related initiatives described in Section 27.

10. CODE OF ETHICS FOR MANAGEMENT AND LEADERSHIP

10.1 Board of Directors / Board of Governors

Exercise oversight of the Institution in the best interests of students, staff, stakeholders and society.
Make decisions transparently, fairly and in accordance with applicable law and this Policy.
Declare and abstain from voting on matters in which they have a personal interest.
Not use their position for personal gain or to benefit related parties improperly.
Receive and review the Annual Ethics Report and Ethics KPI dashboard described in Sections 20 and 22 at least once per year.

10.2 Senior Management (Vice Chancellor, Principal, Chief Executive and equivalent)

Lead by example and model the ethical values set out in this Policy.
Create and maintain a culture of ethical conduct and integrity throughout the Institution.
Ensure that this Policy is communicated, understood and enforced at all levels.
Act decisively and fairly in responding to reports of misconduct or unethical behaviour.
Ensure adequate resources are allocated to ethics governance and training.
Ensure their Institution meets the ethics training completion targets set out in Section 21 and contributes accurate data to the KPI framework in Section 20.

10.3 Heads of Department / Programme Coordinators

Monitor compliance with this Policy within their departments and programmes.
Address minor breaches at the departmental level in accordance with institutional procedures.
Ensure that staff under their supervision receive ethics orientation and training.
Report significant breaches to the Ethics Committee promptly.

11. ACADEMIC INTEGRITY

11.1 Definition and Scope

Academic integrity means a commitment to honesty, trust, fairness, respect, responsibility and courage in all academic endeavours. All forms of academic dishonesty are strictly prohibited, including:

Type of Breach	Definition / Examples
Plagiarism	Presenting another person’s work, words, ideas or data as one’s own without proper attribution, whether from print, digital or AI sources.
Cheating	Using unauthorised materials, assistance or means in examinations or assessments.
Fabrication	Inventing or falsifying data, results, citations or other information in any academic submission.
Falsification	Manipulating research materials, equipment, processes or data so as to misrepresent results.
Collusion	Collaborating with others without authorisation in completing assessed work intended to be individual.
Contract Cheating	Commissioning or submitting work prepared by a third party, including AI tools, in violation of assessment rules.
Impersonation	Sitting an examination or completing assessed work on behalf of another student, or vice versa.
Self-Plagiarism	Re-submitting substantially similar work for which academic credit has already been obtained, without disclosure.

11.2 AI-Generated Content

The use of artificial intelligence (AI) tools in academic work shall be governed by the specific assessment guidelines published by each academic department and by the principles set out in Section 14 (AI Ethics and Responsible Technology). Undisclosed or unauthorised use of AI-generated content shall be treated as academic misconduct in accordance with this Policy.

11.3 Responsibilities

Academic staff are responsible for designing assessments that promote academic integrity, using approved plagiarism detection tools, and reporting suspected breaches promptly. Students are responsible for understanding the rules before submission. Institutions are responsible for providing clear guidance and supporting a culture of academic honesty.

12. RESEARCH ETHICS AND INTEGRITY

12.1 Principles of Ethical Research

All research conducted under the auspices of any Institution within the Group shall adhere to the following principles:

Respect for persons — honouring the autonomy and dignity of all research participants.
Beneficence — maximising benefits and minimising harms.
Justice — ensuring fair distribution of the burdens and benefits of research.
Integrity — honest conduct in all aspects of research design, execution, analysis and reporting.
Transparency — openness about methods, data sources, funding and conflicts of interest.

12.2 Research Ethics Review

All research involving human participants, animals, biological materials, or sensitive data shall obtain prior approval from the Institutional Research Ethics Committee (IREC) before commencement, using Form REAA-005 (attached at Part E of this Policy).

12.3 Prohibited Research Conduct

Fabrication, falsification or selective reporting of research data.
Failure to obtain informed consent from research participants.
Research that endangers participants, staff or the public.
Plagiarism in research publications or presentations.
Ghost writing and honorary authorship.
Failure to disclose funding sources or conflicts of interest.

12.4 Open Science and Data Management

The Group encourages researchers to adopt open science practices, including making research data, methods and outputs as openly available as is consistent with legal, ethical, privacy and intellectual property considerations. Every research project involving primary data collection should include a Data Management Plan (DMP) addressing how data will be collected, stored, secured, shared and, where appropriate, made available for verification or re-use by others.

12.5 Research Data Retention

Primary research data, materials and records supporting published findings shall be retained for a minimum of seven (7) years from the date of publication, or longer where required by funder conditions, journal policy, or applicable law (including the PDPA 2010 where personal data is involved).
Research data shall be stored securely in accordance with the Information & Data Classification SOP and the Group’s IT security policies.
Upon the departure of a researcher from the Group, research data and records remain the property of the Institution and must be handed over in accordance with the Asset & Inventory Management Policy.

12.6 Responsible Authorship

Authorship of research outputs shall be determined according to the actual intellectual contribution made by each individual, consistent with internationally recognised authorship criteria (such as those published by the International Committee of Medical Journal Editors, adapted as appropriate to each discipline). In particular:

All listed authors must have made a substantial contribution to the conception, design, execution, analysis or interpretation of the research.
All listed authors must approve the final version of the work and agree to be accountable for its content.
Honorary or ‘gift’ authorship (naming individuals who did not contribute) and ghost-writing (omitting individuals who did contribute, including commercial writers) are prohibited.
The respective contributions of students and supervisors shall be agreed at the outset of a research project and documented, to avoid later disputes.

12.7 Predatory Journals and Conferences

Staff and students shall not submit, publish, or present research in journals, conference proceedings or publishers that meet the characteristics of ‘predatory’ publications — namely those that charge publication fees without providing legitimate editorial services, peer review, or long-term archiving. Researchers are strongly encouraged to verify the legitimacy of a publication venue prior to submission using recognised tools and directories (e.g., Scopus, Web of Science, the Directory of Open Access Journals (DOAJ), or equivalent), and may seek guidance from their Institution’s library or research office. Publication in a venue subsequently identified as predatory shall not be counted toward an individual’s research output for performance appraisal, promotion, or KPI purposes (see Section 20), without prejudice to any separate finding of misconduct.

12.8 Publication Ethics

Duplicate or redundant publication of substantially the same research findings, without disclosure and appropriate cross-referencing, is prohibited.
Researchers shall promptly notify the relevant journal or publisher, and the IREC, of any significant error discovered in a published work, and shall cooperate with any resulting correction, retraction, or expression of concern, in line with COPE guidelines.
Conflicts of interest relevant to a publication (including funding sources) shall be disclosed to the publisher in accordance with Section 13 of this Policy.
The Group will maintain a record of retractions, corrections and expressions of concern relating to its researchers’ publications as part of the Research Ethics Register, for review by the IREC and reporting under Section 20.

13. CONFLICT OF INTEREST

13.1 Definition

A conflict of interest arises when a person’s private or personal interests could improperly influence — or appear to influence — the exercise of their official duties, responsibilities or judgement.

13.2 Examples of Conflicts of Interest

Participating in a procurement decision where one has a financial interest in a supplier.
Supervising or assessing a student who is a family member or close associate.
Accepting gifts, hospitality or other benefits from vendors or students.
Holding an outside employment or directorship that competes with or conflicts with duties.
Using institutional resources, information or relationships for private benefit.

13.3 Disclosure and Management

All staff and management shall promptly disclose any actual, potential or perceived conflict of interest using Form CIDF-002.
Upon disclosure, the Ethics Committee or designated officer shall assess the situation and determine appropriate management measures.
Where a conflict cannot be adequately managed, the person concerned shall be required to recuse themselves from the relevant matter.
Failure to disclose a known conflict of interest constitutes a serious breach of this Policy.
Annual declarations of interest shall be completed by all staff in management and oversight roles.

14. AI ETHICS AND RESPONSIBLE TECHNOLOGY

14.1 Policy Statement

BAC Education Group recognises both the significant opportunities and the ethical risks presented by artificial intelligence (AI) in education, research and administration. The Group is committed to the responsible, transparent and accountable use of AI, aligned with Malaysia’s AI Governance and Ethics (AIGE) Guidelines (MOSTI, 2024) and international good practice. The Group aspires to be a sector leader in the ethical use of AI in Malaysian private higher education.

14.2 Responsible AI Principles

All use of AI tools and systems within the Group — whether for teaching, assessment, research, administration, or marketing — shall be guided by the following principles:

Principle	What it Means in Practice
Transparency	Staff, students and other stakeholders must be informed when AI is used in a way that materially affects them (e.g., AI-assisted grading, AI-driven admissions screening, AI chatbots for student support). The use of AI must not be concealed.
Human Oversight	AI tools may support but shall not replace human judgement in decisions that materially affect a person’s academic standing, employment, or rights (e.g., final grades, disciplinary findings, admissions decisions, performance appraisals). A qualified human must review and is accountable for such decisions.
Data Protection	Use of AI tools must comply with the PDPA 2010 and the Information & Data Classification SOP. Personal data (including student records) must not be input into public/unapproved AI tools. Only AI tools approved under the ICT & e-Learning Policy’s tool-approval process may be used with institutional data.
Bias Mitigation	Where AI tools are used in admissions, assessment, or recruitment, the Group shall take reasonable steps to assess and mitigate the risk that such tools produce biased or discriminatory outcomes, consistent with Section 3 (Human Rights, Equity and Inclusion).
Accountability	Each AI tool in use must have a designated institutional owner accountable for its appropriate use, in line with the Group AI Governance Policy.
Academic Integrity	Use of AI in academic work is governed by Section 11.2 and departmental assessment guidelines; undisclosed AI use in submitted work is academic misconduct.

14.3 Ethical Use in Teaching

Academic staff may use approved AI tools to support lesson planning, content creation and administrative tasks, provided that the final responsibility for course content and learning outcomes remains with the academic staff member.
Where AI-generated content is used in teaching materials, its origin should be identifiable to students where relevant to their learning (e.g., in academic writing or critical evaluation exercises).

14.4 Ethical Use in Assessment

Departments must specify, for each assessment, whether and how AI tools may be used by students, and communicate this clearly (see also Section 11.2).
Where AI tools are used by staff to assist in marking or generating feedback, a qualified academic must review the AI-assisted output before it is released to students, in line with the Human Oversight principle (Section 14.2).
AI-based proctoring and plagiarism-detection tools used under the ICT & e-Learning Policy must be approved tools, and any AI-flagged finding of misconduct must be independently reviewed by a human investigator under Section 17 before any sanction is imposed.

14.5 Ethical Use in Research

Researchers using AI tools for literature review, data analysis, writing assistance, or other research tasks must disclose such use in accordance with the policies of the relevant journal, funder, and the Group’s research integrity requirements (Section 12).
AI tools must not be listed as authors of research outputs (consistent with Section 12.6 on Responsible Authorship); responsibility for the accuracy and integrity of AI-assisted research outputs rests with the human researcher(s).
Use of AI tools to fabricate or falsify research data is prohibited and constitutes a serious breach of Section 12.3.

14.6 Governance and Cross-Reference

The detailed governance framework for AI within the Group — including the approval process for new AI tools, the five-level Group AI Use Scale, risk classification, vendor due diligence, and monitoring — is set out in the Group AI Governance Policy, which is grounded in the AIGE Guidelines (MOSTI, 2024), the PDPA 2010, and MQA advisory guidance on AI in higher education. This Policy and the Group AI Governance Policy shall be read together, and any conflict shall be resolved in favour of the stricter standard.

14.7 Reporting Concerns

Any concern that an AI tool or system is being used in a manner inconsistent with this Section — including suspected bias, lack of transparency, or absence of human oversight — may be reported using Form ECF-001 and shall be handled under Sections 16-19 of this Policy.

PART C: GOVERNANCE, REPORTING AND ENFORCEMENT

15. ETHICS GOVERNANCE STRUCTURE

15.1 Group Ethics and Integrity Committee (GEIC)

The Board of Directors of BAC Education Group shall establish a Group Ethics and Integrity Committee (GEIC) with the following composition and responsibilities:

Position	Role in GEIC
Group Chief Executive Officer or nominee	Chairperson
Head of Group Legal / Compliance	Secretary
Head of Group Human Resources	Member
Head of Group Academic Affairs	Member
Head of Group Student Affairs	Member
Independent Non-Executive Member (external appointment)	Member
Institutional Representatives (one per institution, rotating)	Members
Head of Group Sustainability / ESG (or equivalent)	Member
Head of Group IT / Data Protection Officer	Member (for AI ethics and data protection matters)

The GEIC shall meet at least twice per year and shall be responsible for:

Overseeing the implementation and review of this Policy across all institutions.
Receiving and reviewing reports from Institutional Ethics Committees.
Determining appropriate sanctions for serious or Group-level misconduct.
Reporting on ethics and integrity matters to the Board of Directors.
Reviewing the Ethics KPI dashboard (Section 20) at each meeting and the Annual Ethics Report (Section 22) at least once per year.
Overseeing the mandatory ethics training programme (Section 21) and monitoring completion rates across the Group.

15.2 Institutional Ethics Committee (IEC)

Each Institution within the Group shall establish its own Institutional Ethics Committee (IEC) comprising:

Principal / Vice Chancellor / Chief Executive (Chairperson)
Head of Academic Affairs (Member)
Head of Student Affairs (Member)
Head of Human Resources (Member)
Legal Advisor or Compliance Officer (Secretary)
Two (2) elected academic staff representatives (Members)
One (1) student representative — for matters involving student conduct (Member)
One (1) representative responsible for accessibility / disability support (Member, for matters involving Section 3)

The IEC shall be responsible for receiving, investigating and resolving ethics complaints at the institutional level, subject to escalation to the GEIC for serious matters.

16. REPORTING MECHANISM AND WHISTLEBLOWING

16.1 How to Make a Report

Any person who witnesses, suspects or becomes aware of a breach of this Policy may report it through the following channels:

Channel	Contact / Details
In-person / Written Report	Submit Form ECF-001 to the Institutional Ethics Committee Secretary or Group Compliance Office.
Email (Institutional)	ethics@[institution].edu.my (dedicated ethics email for each institution).
Group Ethics Hotline	ethics@baceducation.edu.my (Group level, monitored by GEIC Secretary).
Anonymous Reporting	Via the Group anonymous online reporting portal or drop box at each campus.

16.2 Whistleblower Protections

The Group is committed to protecting all persons who make reports in good faith. In accordance with the Whistleblower Protection Act 2010 (Act 711):

No person shall be subject to retaliation, victimisation, disciplinary action or any detriment for making a bona fide report.
The identity of the reporting person shall be kept confidential to the extent possible.
Any person found to have victimised a whistleblower shall be subject to disciplinary action.
Knowingly making a false or malicious report is a breach of this Policy.

17. INVESTIGATION PROCEDURES

Upon receipt of a report, the following steps shall be taken:

Step	Action	Responsible Party	Timeline
1	Acknowledge receipt of the complaint to the complainant (if not anonymous).	IEC Secretary	Within 3 working days
2	Conduct preliminary assessment to determine if the complaint is within scope and prima facie founded.	IEC Chairperson	Within 5 working days
3	If prima facie case established, formally initiate investigation and notify the respondent.	IEC Chairperson	Within 7 working days
4	Appoint an Investigation Panel (minimum 3 members, independent of the matter).	IEC Chairperson	Within 10 working days
5	Investigation Panel gathers evidence, interviews witnesses and respondent, and prepares report.	Investigation Panel	Within 30 working days
6	IEC reviews Investigation Panel report and makes determination of facts.	IEC	Within 10 working days of receiving panel report
7	IEC recommends appropriate sanction or action to the relevant authority.	IEC	Together with Step 6
8	Final decision communicated to all relevant parties. Right of appeal noted.	IEC Chairperson / GEIC	Within 5 working days of decision
9	Case logged in the Ethics Complaint Register with category and outcome data for KPI reporting purposes (Section 20).	IEC Secretary	Upon closure

Principles of natural justice shall be applied throughout the investigation. The respondent shall be given a fair opportunity to present their case. Investigations shall be conducted confidentially. Timelines may be extended for complex matters with appropriate notification.

18. DISCIPLINARY ACTION AND SANCTIONS

18.1 Range of Sanctions

Following a finding of misconduct, the following sanctions may be imposed, having regard to the severity of the breach, the circumstances and any mitigating factors:

Category	Nature of Breach	Possible Sanctions
Minor	First or isolated breach; limited impact; no ill intent.	Verbal warning; written warning; mandatory ethics training.
Moderate	Repeated minor breaches; deliberate but not egregious breach; moderate harm.	Written reprimand; suspension of duties/privileges; demotion; loss of increment; probation.
Serious	Deliberate, significant or repeated breach; substantial harm; fraud, corruption, harassment.	Suspension without pay; termination of employment / enrolment; debarment; referral to authorities.
Very Serious	Criminal conduct; severe harm to persons; fraud involving large sums; gross academic misconduct.	Immediate dismissal; referral to relevant authorities (MACC, Police); notation on academic/employment record.

18.2 Students

In addition to the above, sanctions applicable to students may include: academic penalty (zero mark, fail grade); suspension from examinations; suspension from the Institution; cancellation of enrolment; withdrawal of academic award; and notation on academic transcript.

18.3 Right of Appeal

Any person subject to a disciplinary sanction has the right to appeal in writing to the GEIC within fourteen (14) calendar days of receiving the decision. The GEIC shall constitute an independent Appeal Panel whose decision shall be final and binding.

19. PROTECTION AGAINST VICTIMISATION

The Group expressly prohibits any form of retaliation, victimisation or detrimental treatment against:

A person who has reported a suspected breach of this Policy in good faith.
A person who has participated as a witness in an investigation under this Policy.
A person who has exercised any right under this Policy.

Any conduct amounting to victimisation shall itself constitute a serious breach of this Policy and shall be dealt with through disciplinary proceedings.

20. ETHICS PERFORMANCE MONITORING AND KPIs

20.1 Purpose

The Group shall monitor the implementation and effectiveness of this Policy through a defined set of Key Performance Indicators (KPIs), enabling the Board, GEIC, Senate/Academic Board and external stakeholders (including QS and MQA) to assess evidence of impact, not merely the existence of policy and governance structures.

20.2 Core Ethics KPIs

Each Institution shall track and report the following KPIs, at minimum, on an annual basis using Form AEKR – 007 (Annual Ethics KPI & Performance Report):

KPI	Description	Target / Benchmark
Ethics complaints received	Total number of complaints received via Form ECF- 001, by category (academic integrity, harassment, COI, etc.) and by Institution.	Trend monitored; no fixed target (under-reporting is also a risk)
Ethics complaints resolved	Number and % of complaints resolved within the timelines in Section 17.	≥ 90% within timeline
Academic misconduct cases	Number of AIIR-003 cases, by type of breach (Section 11.1) and by outcome.	Trend monitored
Research ethics approvals	Number of REAA-005 applications received, approved, and average turnaround time.	Turnaround ≤ 30 working days
Staff ethics training completion rate	% of staff completing induction and annual refresher training (Section 21).	100% within 90 days of due date
Student ethics awareness participation	% of new students completing orientation and academic integrity certification (Section 21).	100% of new intake
Whistleblower reports handled	Number of reports received via whistleblowing channels (Section 16), and outcomes (substantiated / not substantiated / ongoing).	Trend monitored
Conflict of interest declarations	% of staff in management/oversight roles completing CIDF-002 by the annual deadline (Section 13.3).	100% by 31 January
Human Rights & Inclusion cases	Number of complaints relating to Section 3, and resolution outcomes.	Trend monitored
AI ethics concerns reported	Number of concerns reported under Section 14.7 and outcomes.	Trend monitored
Research integrity issues	Number of retractions, corrections, or predatory- publication findings under Section 12.7-12.8.	Target: 0

20.3 Monitoring and Escalation

Institutional Ethics Committees shall compile KPI data quarterly and submit it to the GEIC Secretary.
The GEIC shall review aggregated KPI data at each of its meetings (Section 15.1) and identify any adverse trends requiring intervention.
Where an Institution falls materially short of a KPI target (e.g., training completion below 80%), the GEIC shall require a remediation plan from that Institution’s senior management within 30 days.

20.4 Use of KPI Data

KPI data shall be used to: (a) inform the Annual Ethics Report (Section 22); (b) support institutional self – assessment for MQA, QS and other quality frameworks; and (c) inform resource allocation decisions by the Board. KPI data reported externally shall be aggregated and anonymised so as not to disclose information about identifiable individuals or specific cases.

21. MANDATORY ETHICS TRAINING AND AWARENESS

21.1 Staff Induction Ethics Training

All new staff (academic and non-academic, including contract and part-time staff) shall complete a mandatory Ethics, Integrity and Responsible Conduct induction training module within thirty (30) calendar days of commencing employment. The module shall cover, at minimum: an overview of this Policy; the Code of Ethics relevant to the staff member’s role (Sections 7-10); reporting channels (Section 16); conflict of interest obligations (Section 13); and an introduction to Human Rights & Inclusion (Section 3) and AI Ethics (Section 14).

21.2 Annual Refresher Training

All staff shall complete an annual ethics refresher training module, which may be delivered online via the LMS. Completion of the annual refresher is a pre-condition for completing Section B of the Annual Ethics Compliance Declaration (Form AECD-004). Heads of Department are responsible for ensuring staff under their supervision complete this requirement (Section 10.3).

21.3 Student Ethics Orientation

All new students shall complete a mandatory ethics orientation as part of their institutional induction, covering: the Code of Ethics for Students (Section 9); academic integrity expectations (Section 11); reporting channels (Section 16); and an introduction to Human Rights & Inclusion (Section 3).

21.4 Academic Integrity Certification

In addition to the general orientation, all students shall complete an Academic Integrity Certification — a short assessment confirming understanding of plagiarism, citation, collusion, contract cheating and AI-use rules (Sections 11 and 14) — prior to the submission of their first assessed work. Programmes may integrate this certification into an existing induction module rather than deliver it as a stand-alone activity.

21.5 Records and Tracking

Completion of training under this Section shall be recorded using Form ETCR-006 (Ethics & Integrity Training Completion Record) or the equivalent LMS completion record, and shall feed into the KPI framework under Section 20. SOP 4 (Ethics Training Delivery and Tracking Procedure) sets out the operational process for delivering and tracking this training.

22. ANNUAL ETHICS REPORT AND EXTERNAL DISCLOSURE

22.1 Annual Ethics Report

The GEIC shall prepare an Annual Ethics Report covering the preceding calendar year, drawing on the KPI data compiled under Section 20. The Annual Ethics Report shall be presented to the Board of Directors and, for matters relevant to academic governance, to the Senate / Academic Board of each Institution.

22.2 Contents

The Annual Ethics Report shall include, at minimum:

Aggregated ethics complaint statistics by category and Institution (Section 20.2).
Academic misconduct trends and any systemic issues identified.
Research ethics and research integrity statistics, including any retractions or predatory-publication findings (Section 12).
Ethics, integrity and academic-integrity training completion rates (Section 21).
Whistleblower report statistics and outcomes (in aggregate, preserving confidentiality).
Human Rights & Inclusion statistics (Section 3) and progress on accessibility initiatives.
AI ethics matters arising under Section 14.
Sustainability and ESG ethics initiatives and progress against the commitments in Section 27.
Key integrity initiatives undertaken during the year and planned for the following year.

22.3 External Publication

Following Board approval, a summary version of the Annual Ethics Report — comprising aggregated statistics, integrity initiatives, training participation rates and academic misconduct trends, with all information anonymised and de-identified so that no individual case or person can be identified — may be published on the website of the Group and/or relevant Institutions, and may be used to support QS Stars, MQA and other quality assurance submissions.

22.4 Confidentiality Safeguards

Nothing in this Section permits the disclosure of information that would identify, or could reasonably lead to the identification of, any complainant, respondent, witness, or research subject. The GEIC Secretary shall review any externally-facing summary prior to publication to confirm compliance with this Section and with the PDPA 2010.

PART D: SPECIFIC POLICIES

23. ANTI-BRIBERY AND ANTI-CORRUPTION

23.1 Zero Tolerance

The Group operates a zero-tolerance policy against all forms of bribery and corruption. No staff member, management personnel, student, contractor or agent shall offer, give, request or receive any bribe, corrupt payment or improper advantage, directly or indirectly, in connection with any business or matter involving the Group.

23.2 Gifts, Hospitality and Entertainment

Category	Policy
Token gifts (value ≤ RM100)	May be accepted; must be declared to the Head of Department.
Gifts (value > RM100)	Must be declined or surrendered to the Institution; recorded in the Gifts Register.
Cash gifts of any amount	Must be declined in all circumstances.
Gifts from students	Academic staff shall decline gifts from current students during a teaching/assessment period.
Corporate hospitality	Modest and infrequent; must not create an obligation; prior approval required if value > RM200.

23.3 Facilitation Payments

Facilitation payments (small payments made to expedite routine government actions) are prohibited. Any demand for such payments must be reported immediately to the Group Compliance Office.

24. SEXUAL HARASSMENT AND DIGNITY AT WORK

24.1 Policy Statement

The Group is committed to maintaining a work and study environment free from sexual harassment and all forms of harassment, bullying and intimidation. All persons at any Institution are entitled to be treated with dignity and respect.

24.2 Definition

Sexual harassment means any unwanted conduct of a sexual nature (whether verbal, non-verbal, physical or visual) that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment. This includes but is not limited to: unwelcome sexual advances; requests for sexual favours; sexual comments, jokes or innuendo; and transmission of sexually explicit materials.

24.3 Obligations and Reporting

All staff and students must report incidents of sexual harassment.
Complaints shall be handled with sensitivity, urgency and strict confidentiality.
The Institution shall provide support services to complainants.
Substantiated sexual harassment is a serious breach and shall result in disciplinary action up to and including dismissal.
Sexual harassment involving a minor shall be reported to the relevant authorities.

25. DATA PRIVACY AND CONFIDENTIALITY

25.1 Obligations under the Personal Data Protection Act 2010

All Institutions within the Group are data users under the Personal Data Protection Act 2010 (PDPA). All staff handling personal data of students, staff or third parties shall:

Collect only personal data that is necessary for a legitimate institutional purpose.
Not disclose personal data to unauthorised parties.
Implement reasonable technical and organisational security measures to protect personal data.
Retain personal data only for as long as necessary and dispose of it securely.
Comply with requests from data subjects to access or correct their personal data.
Where personal data is processed using AI tools, comply additionally with Section 14 (AI Ethics and Responsible Technology).

25.2 Confidential Information

Staff must maintain the confidentiality of institutional strategies, financial data, legal matters, student records, staff personnel files and any other information designated as confidential. This obligation continues after the termination of employment.

26. USE OF TECHNOLOGY AND SOCIAL MEDIA

26.1 Acceptable Use

Institutional IT systems (computers, networks, email, online platforms) are provided for legitimate academic and administrative purposes. Incidental personal use is permitted where it does not interfere with duties, consume significant resources or breach any law or institutional policy.

26.2 Prohibited Conduct — Technology

Accessing, downloading or distributing illegal, obscene or harmful content.
Attempting to circumvent IT security measures or access unauthorised systems.
Using institutional IT resources for personal commercial activities.
Installing unauthorised software.
Sharing login credentials.
Inputting confidential, personal, or institutional data into AI tools that have not been approved in accordance with the ICT & e-Learning Policy and Section 14 of this Policy.

26.3 Social Media

All staff and students shall exercise responsibility in their use of social media. When posting content that relates to the Institution, colleagues, students or any institutional matter, they shall:

Not make defamatory, discriminatory or harassing statements about any person.
Not disclose confidential or sensitive institutional information.
Not impersonate the Institution or make unauthorised statements on its behalf.
Be aware that online conduct can constitute misconduct under this Policy.

27. SUSTAINABILITY AND ESG ETHICS

27.1 General Commitment

The Group is committed to sustainable and socially responsible operations. All staff, students and stakeholders are encouraged to:

Minimise waste and energy consumption in campus operations.
Respect and protect the environment in all institutional activities.
Support community engagement, volunteerism and outreach programmes.
Promote inclusive and respectful campus cultures that celebrate diversity.
Ensure procurement and supply chain decisions consider ethical, environmental and social criteria.

27.2 Commitment to the UN Sustainable Development Goals (SDGs)

The Group recognises the United Nations Sustainable Development Goals (SDGs) as a global framework for sustainable development and aligns its institutional strategy with the SDGs most relevant to its mission as an education provider, in particular: SDG 4 (Quality Education), SDG 5 (Gender Equality), SDG 8 (Decent Work and Economic Growth), SDG 10 (Reduced Inequalities), SDG 12 (Responsible Consumption and Production), SDG 13 (Climate Action), and SDG 16 (Peace, Justice and Strong Institutions — reflected throughout this Policy). Each Institution shall identify, in its annual planning, specific initiatives that contribute to these goals, for inclusion in the Annual Ethics Report (Section 22).

27.3 Responsible Procurement

Procurement decisions shall, where practicable, take into account the environmental and social track record of suppliers and contractors, in addition to the anti-corruption requirements in Section 23 and the procurement obligations in Section 8.3.
Preference shall be given, where commercially reasonable, to suppliers who demonstrate ethical labour practices, environmental responsibility, and (where relevant) local community benefit.
Investment of the Group’s funds, including endowment and reserve funds, shall be conducted in accordance with the Sustainable Investing Policy (BAC-SIP-2025-003), which incorporates ESG screening criteria.
Acceptance of donations and funding shall be conducted in accordance with the Sustainable Funding and Donations Policy (BAC-SFDP-2025-002), which incorporates donor due-diligence and ethical acceptance criteria.

27.4 Carbon Reduction and Environmental Targets

Each Institution shall measure and report, at minimum annually, key environmental indicators such as electricity consumption, water consumption, and waste generated, with a view to establishing baselines and setting year-on-year reduction targets.
The Group shall explore opportunities to reduce its carbon footprint through energy efficiency, responsible facilities management, reduced paper usage (supported by digital systems under the ICT & e-Learning Policy), and sustainable travel policies.
Progress against environmental targets shall be reported in the Annual Ethics Report (Section 22) and may be referenced in QS Sustainability and similar submissions.

27.5 Social Impact and Community Engagement

Each Institution shall maintain and report on community engagement initiatives, including volunteering programmes, scholarships for underprivileged students, outreach to underserved communities, and partnerships with civil society organisations.
Students and staff are encouraged to participate in such initiatives as part of their holistic development (see Sections 7.1 and 9.4).

27.6 Responsible Technology

The Group’s commitment to ESG extends to its use of technology. In particular, the Group shall consider the environmental impact of its IT infrastructure (e.g., energy-efficient data centres and cloud services where feasible) and shall ensure that its use of AI and other digital technologies is consistent with the ethical principles set out in Section 14 (AI Ethics and Responsible Technology), including fairness, transparency and human oversight, which the Group regards as integral to its social governance obligations.

PART E: STANDARD OPERATING PROCEDURES AND FORMS

SOP 1: ETHICS COMPLAINT / REPORTING PROCEDURE

SOP Reference	BAC-SOP-EC-001
Applies To	All Staff, Students, Management — All Institutions
Owner	Group Ethics and Integrity Committee (GEIC)
Version	1.0 \| Effective 01 July 2025

Purpose

To establish a consistent, fair and confidential procedure for receiving, processing and resolving ethics complaints across all Institutions within the Group.

Procedure

Step	Action	Person Responsible	Timeline	Document
1	Complainant becomes aware of potential ethics breach.	Complainant	Upon awareness	—
2	Complainant completes Form ECF-001 and submits to IEC Secretary (or GEIC for Group- level matters). Anonymous complaints may be submitted via the anonymous portal or drop box.	Complainant	ASAP	Form ECF-001
3	IEC Secretary logs complaint in the Ethics Complaint Register and issues acknowledgement to complainant (if not anonymous).	IEC Secretary	Within 3 working days	Ethics Register
4	IEC Chairperson conducts preliminary screening: Is the complaint within scope? Is it prima facie substantiated? Is it frivolous/malicious?	IEC Chairperson	Within 5 working days	Screening Note
5a	If frivolous or outside scope: Close complaint and notify complainant with reasons.	IEC Chairperson	Within 5 working days of screening	Closure Notice
5b	If prima facie case: Formally open investigation, notify respondent (without disclosing complainant identity where possible), appoint Investigation Panel.	IEC Chairperson	Within 7 working days of screening	Investigation Commencement Notice
6	Investigation Panel gathers evidence (documents, interviews, site visits as necessary).	Investigation Panel	Within 30 working days	Investigation Report

7	Respondent given written opportunity to respond to findings (Show Cause).	Investigation Panel	During investigation	Show Cause Letter & Response
8	Investigation Panel submits report and recommendation to IEC.	Investigation Panel	Upon completion	Investigation Report
9	IEC deliberates and makes finding and recommendation on sanction.	IEC	Within 10 working days	IEC Resolution
10	IEC recommendation submitted to relevant authority (Head of Institution / GEIC) for decision.	IEC Chairperson	Within 5 working days	Decision Letter
11	Decision communicated to complainant and respondent. Right of appeal (14 calendar days) explained.	IEC Chairperson	Within 5 working days of decision	Decision Letter
12	Sanction implemented and monitored.	HR / Academic Affairs	Per decision	Sanction Record
13	Case closed and filed confidentially.	IEC Secretary	Upon completion of sanction	Ethics Register
14	Case category and outcome data extracted (anonymised) for the Ethics KPI dashboard (Section 20).	IEC Secretary	Quarterly	KPI Dataset

Key Principles

Natural justice: respondent has the right to know allegations and respond.
Confidentiality: identities and details protected throughout.
Timeliness: all timelines shall be adhered to; extensions require GEIC approval.
Proportionality: sanctions commensurate with severity of breach.

SOP 2: CONFLICT OF INTEREST DISCLOSURE PROCEDURE

SOP Reference	BAC-SOP-COI-002
Applies To	All Staff and Management — All Institutions
Owner	Group Ethics and Integrity Committee (GEIC)
Version	1.0 \| Effective 01 July 2025

Purpose

To ensure that all actual, potential or perceived conflicts of interest are identified, disclosed and managed appropriately, protecting the integrity of institutional decision-making.

Triggering Events

A disclosure shall be made when a staff member or manager:

Is newly appointed or commences a new role.
Becomes aware of a new interest that could conflict with their duties.
Is assigned to a committee, tender, assessment or decision-making process in which a conflict may arise.
Completes the annual declaration cycle (January each year).

Procedure

Step	Action	Person Responsible	Timeline
1	Staff member identifies actual, potential or perceived conflict of interest.	Staff / Manager	Upon awareness
2	Staff member completes Form CIDF-002 and submits to direct supervisor and IEC Secretary.	Staff / Manager	Within 5 working days of awareness
3	Supervisor assesses the disclosed conflict in consultation with IEC Secretary.	Supervisor + IEC Secretary	Within 5 working days
4a	If no conflict: Confirm in writing; retain CIDF-002 on file.	IEC Secretary	Within 3 working days of assessment
4b	If conflict confirmed: Determine management measures (recusal, divestment, supervision, etc.).	IEC / Head of Institution	Within 10 working days
5	Management measures implemented and recorded.	HR / IEC Secretary	Per agreed plan
6	Annual review: all staff in management/oversight roles complete Form CIDF-002 by 31 January each year.	All relevant staff	31 January annually
7	IEC Secretary maintains Conflict of Interest Register.	IEC Secretary	Ongoing
8	Annual completion rate (% of required staff) reported to KPI dashboard (Section 20).	IEC Secretary	By 15 February annually

SOP 3: ACADEMIC INTEGRITY INVESTIGATION PROCEDURE

SOP Reference	BAC-SOP-AI-003
Applies To	All Academic Staff and Students — All Institutions
Owner	Academic Affairs / Institutional Ethics Committee
Version	1.0 \| Effective 01 July 2025

Purpose

To provide a clear, fair and consistent procedure for investigating and resolving suspected breaches of academic integrity.

Procedure

Step	Action	Person Responsible	Timeline
1	Academic staff member suspects or detects potential academic misconduct (e.g. plagiarism detected via Turnitin or other tool, including AI-detection tools; suspicious examination behaviour).	Academic Staff Member	Upon detection
2	Academic staff member completes Form AIIR-003 and submits to Head of Department (HoD).	Academic Staff Member	Within 2 working days of detection
3	HoD reviews the report. If clearly minor and first offence: HoD may handle informally (verbal warning + counselling). If serious or repeated: escalate to IEC Academic Integrity Panel.	HoD	Within 5 working days
4	Student notified in writing of the allegation and invited to respond within 7 working days.	HoD / IEC Secretary	Within 5 working days of escalation
5	Student submits written response and may request a hearing.	Student	Within 7 working days
6	Academic Integrity Panel reviews evidence and student’s response; may convene a hearing.	Academic Integrity Panel	Within 15 working days
7	Panel makes finding and recommends sanction.	Academic Integrity Panel	Within 5 working days of hearing
8	Decision communicated to student. Right of appeal within 14 days.	HoD / IEC	Within 5 working days of decision
9	Sanction implemented (e.g., mark penalty, fail grade, suspension).	Academic Registry / HR	Per decision
10	Case recorded in Academic Integrity Register.	IEC Secretary	Upon closure
11	Case data (anonymised, by breach type) reported to KPI dashboard (Section 20).	IEC Secretary	Quarterly

SOP 4: ETHICS TRAINING DELIVERY AND TRACKING PROCEDURE

SOP Reference	BAC-SOP-ETT-004
Applies To	All Staff and Students — All Institutions
Owner	Group Human Resources / Academic Affairs, with GEIC oversight
Version	1.0

Purpose

To ensure that all staff and students complete the mandatory ethics training and awareness activities required under Section 21, and that completion is accurately tracked for KPI reporting under Section 20.

Procedure

Step	Action	Person Responsible	Timeline
1	HR issues induction ethics training module to new staff via LMS upon commencement of employment.	HR / L&D	Day 1 of employment
2	New staff member completes induction training module.	New Staff	Within 30 calendar days of commencement
3	LMS records completion; HR exception-reports any staff who have not completed within the deadline to the Head of Department.	HR / L&D	Day 31
4	All staff complete annual refresher training module via LMS.	All Staff	By 30 November annually
5	Academic Affairs issues student ethics orientation and Academic Integrity Certification as part of new- student induction.	Academic Affairs / Programme Office	During orientation week
6	New students complete orientation and certification before first assessed submission.	New Students	Before first assessment
7	LMS/HR system generates completion data; Form ETCR-006 used for any training delivered outside the LMS (e.g., in-person sessions).	HR / Academic Affairs	Ongoing
8	Completion rates compiled and submitted to GEIC Secretary for the KPI dashboard (Section 20).	HR / Academic Affairs	Quarterly
9	Where completion rate < 80% for any Institution, GEIC requests remediation plan from senior management (Section 20.3).	GEIC	Within 30 days of identification

BAC EDUCATION GROUP

Brickfields Asia College | IACT College | Reliance College | Veritas University College | UNIMY

ETHICS COMPLAINT / REPORTING FORM

Form Reference	ECF-001 \| Version 1.0
Version / Date	01 July 2025
Institution	☐ Brickfields Asia College ☐ IACT College ☐ Reliance College ☐ Veritas University College ☐ UNIMY

SECTION A: COMPLAINANT DETAILS (Leave blank if anonymous)

Full Name: ____________________________________________________________ Staff ID / Student ID / External Party:

____________________________________________________________ Department / Programme / Organisation:

____________________________________________________________ Contact Email: ____________________________________________________________ Contact Phone: ____________________________________________________________

Do you wish to remain anonymous?

☐ Yes — I understand that anonymous complaints may limit the scope of investigation.

☐ No — I consent to my identity being disclosed to the Investigation Panel if necessary.

SECTION B: SUBJECT OF COMPLAINT (RESPONDENT)

Name of Person(s) Complained Against:

____________________________________________________________ Designation / Role: ____________________________________________________________ Department / Programme: ____________________________________________________________

Relationship to Complainant:

☐ Academic Staff ☐ Non-Academic Staff ☐ Management / Leadership ☐ Student ☐ Third Party / Vendor / Contractor

SECTION C: NATURE OF COMPLAINT

Category of Alleged Breach (tick all that apply):

☐ Academic Misconduct / Breach of Academic Integrity ☐ Bribery / Corruption / Fraud ☐ Conflict of Interest — Undisclosed ☐ Sexual Harassment ☐ Harassment / Bullying / Discrimination ☐ Misuse of Institutional Resources ☐ Data Privacy Breach ☐ Research Ethics / Integrity Breach ☐ Misuse of Social Media / Technology ☐ Abuse of Authority ☐ Discrimination / Lack of Accessibility (Human Rights & Inclusion) ☐ AI Ethics Concern (e.g. lack of transparency, bias, no human oversight) ☐ Other (please specify): _____________________________

SECTION D: DETAILS OF THE COMPLAINT

Date(s) of Incident: ____________________________________________________________ Location of Incident: ____________________________________________________________

Description of Incident (attach additional sheets if necessary):

SECTION E: EVIDENCE AND WITNESSES

Supporting Documents / Evidence Attached:

☐ Emails / Messages ☐ Documents / Reports ☐ Photographs / Videos ☐ Other: _____________________________

Name(s) of Witnesses (if any): ____________________________________________________________

SECTION F: DECLARATION

I declare that the information provided in this form is true and accurate to the best of my knowledge. I understand that knowingly making a false or malicious report is a breach of the BAC Education Group Ethics Policy and may subject me to disciplinary action.

Signature Designation

Name (Block Letters) Date

FOR OFFICIAL USE ONLY:

Date Received	Received By	Log No.	Initial Assessment

BAC EDUCATION GROUP

Brickfields Asia College | IACT College | Reliance College | Veritas University College | UNIMY

CONFLICT OF INTEREST DECLARATION FORM

Form Reference	CIDF-002 \| Version 1.0
Version / Date	01 July 2025
Institution	☐ Brickfields Asia College ☐ IACT College ☐ Reliance College ☐ Veritas University College ☐ UNIMY

SECTION A: DECLARANT DETAILS

Full Name: ____________________________________________________________ Staff ID: ____________________________________________________________ Designation / Position: ____________________________________________________________ Department: ____________________________________________________________ Date of Declaration: ____________________________________________________________

Type of Declaration:

☐ Initial Declaration (upon appointment or new role) ☐ Ad Hoc Declaration (triggered by new interest or assignment) ☐ Annual Declaration (for year ending 31 December ________)

SECTION B: DECLARATION OF INTERESTS

Please complete all sections below. Where no interest exists, state ‘NIL’.

Type of Interest	Details (Name of Entity / Relationship / Nature)	Potential Conflict with Duties?	If Yes, Describe Potential Conflict
Directorship / Shareholding in a company		Yes / No
Outside employment or consultancy		Yes / No
Family member employed at a supplier/vendor		Yes / No
Family member enrolled as student at this Institution		Yes / No
Personal relationship with a student under assessment		Yes / No
Financial interest in any matter before a committee		Yes / No
Any other interest		Yes / No

SECTION C: DECLARATION

I declare that the information above is complete and accurate. I understand my obligation to update this declaration promptly if my circumstances change. I acknowledge that failure to disclose a conflict of interest is a breach of the BAC Education Group Ethics Policy.

Signature Designation

Name (Block Letters) Date

FOR OFFICIAL USE ONLY:

Received By	Date	Assessment Outcome	Management Measures Required
		☐ No Conflict ☐ Conflict Identified

Signature Designation

Name (Block Letters) Date

BAC EDUCATION GROUP

Brickfields Asia College | IACT College | Reliance College | Veritas University College | UNIMY

ACADEMIC INTEGRITY INCIDENT REPORT

Form Reference	AIIR-003 \| Version 1.0
Version / Date	01 July 2025
Institution	☐ Brickfields Asia College ☐ IACT College ☐ Reliance College ☐ Veritas University College ☐ UNIMY

SECTION A: REPORTING STAFF DETAILS

Staff Name: ____________________________________________________________ Staff ID: ____________________________________________________________ Subject / Module: ____________________________________________________________ Programme: ____________________________________________________________ Date of Detection: ____________________________________________________________

SECTION B: STUDENT(S) DETAILS

Student Name	Student ID	Programme	Year / Semester

SECTION C: NATURE OF INCIDENT

Type of Academic Misconduct (tick all that apply):

☐ Plagiarism (from print / digital / AI sources) ☐ Cheating in Examination / Test ☐ Fabrication / Falsification of Data ☐ Collusion (unauthorised collaboration) ☐ Contract Cheating / Commissioning (including undisclosed AI use) ☐ Impersonation ☐ Self-Plagiarism / Duplicate Submission ☐ Other: _____________________________

Assessment / Assignment / Examination Title:

____________________________________________________________

Submission Date / Examination Date:

____________________________________________________________ Similarity / AI-Detection Score (if applicable — attach report):

____________________________________________________________

Brief Description of Incident:

Evidence Attached:

☐ Plagiarism / AI-detection report ☐ Original and submitted work ☐ Invigilator / witness statement ☐ Other: _____________________________

Signature Designation

Name (Block Letters) Date

FOR OFFICIAL USE ONLY:

Received by HoD	Date	Action Taken	Escalated to IEC?
		☐ Informal ☐ Formal	☐ Yes ☐ No

BAC EDUCATION GROUP

Brickfields Asia College | IACT College | Reliance College | Veritas University College | UNIMY

ANNUAL ETHICS COMPLIANCE DECLARATION

Form Reference	AECD-004 \| Version 1.0
Version / Date	01 July 2025
Institution	☐ Brickfields Asia College ☐ IACT College ☐ Reliance College ☐ Veritas University College ☐ UNIMY

This Annual Ethics Compliance Declaration is to be completed by all staff by 31 January each year for the preceding calendar year. It is a condition of continued employment that this declaration be completed honestly and in full.

SECTION A: STAFF DETAILS

Full Name: ____________________________________________________________ Staff ID: ____________________________________________________________ Designation: ____________________________________________________________ Department: ____________________________________________________________ Declaration Period: 1 January ________ to 31 December ________

SECTION B: COMPLIANCE DECLARATIONS

Declaration Statement	Yes	No
I have read and understood the BAC Education Group Ethics Policy.	☐	☐
I have complied with the BAC Education Group Ethics Policy in the past year.	☐	☐
I have completed my Conflict of Interest Declaration (CIDF-002) for this year.	☐	☐
I have not offered or accepted any bribe, corrupt payment or improper advantage.	☐	☐
I have not been involved in any undisclosed conflict of interest.	☐	☐
I have not engaged in any form of harassment, bullying or discrimination.	☐	☐
I have not misused institutional resources, data or confidential information.	☐	☐
I have attended the ethics/integrity training or awareness session this year.	☐	☐
I have reported (or have no knowledge of) ethics breaches by others.	☐	☐
I am aware of the whistleblowing mechanisms available to me.	☐	☐
I have completed my mandatory annual ethics refresher training (Section 21.2).	☐	☐

I have read and understood Section 3 (Human Rights, Equity and Inclusion) and have not engaged in any conduct inconsistent with it.	☐	☐
I have read and understood Section 14 (AI Ethics and Responsible Technology) and have used AI tools (if any) only in accordance with that section and the Group AI Governance Policy.	☐	☐

SECTION C: DECLARATION

I declare that the above statements are true and accurate. I understand that providing false information in this declaration is a serious breach of the BAC Education Group Ethics Policy and may result in disciplinary action.

Signature Designation

Name (Block Letters) Date

FOR OFFICIAL USE ONLY — Reviewed By:

Signature Designation

Name (Block Letters) Date

BAC EDUCATION GROUP

Brickfields Asia College | IACT College | Reliance College | Veritas University College | UNIMY

RESEARCH ETHICS APPROVAL APPLICATION

Form Reference	REAA-005 \| Version 1.1 (Draft)
Version / Date	01 July 2025
Institution	☐ Brickfields Asia College ☐ IACT College ☐ Reliance College ☐ Veritas University College ☐ UNIMY

This form must be completed and approved by the Institutional Research Ethics Committee (IREC) BEFORE commencement of any research involving human participants, animals, sensitive data or biological materials.

SECTION A: RESEARCHER DETAILS

Principal Researcher Name: ____________________________________________________________ Staff ID / Student ID: ____________________________________________________________ Department / School / Faculty: ____________________________________________________________ Programme (if student researcher):

____________________________________________________________ Supervisor Name (for student research):

____________________________________________________________ Co-Researchers (if any): ____________________________________________________________ Contact Email: ____________________________________________________________

SECTION B: RESEARCH DETAILS

Research Title: ____________________________________________________________ Proposed Commencement Date:

____________________________________________________________ Proposed Completion Date: ____________________________________________________________ Funding Source (if any): ____________________________________________________________

Type of Research:

☐ Staff-led Research ☐ Postgraduate Research ☐ Undergraduate / Diploma Final Year Project ☐ Collaborative / External Research

SECTION C: ETHICS CHECKLIST

Question	Yes	No	Details (if Yes)
Does the research involve human participants?	☐	☐
Does the research involve vulnerable populations (minors, prisoners, etc.)?	☐	☐

Will informed consent be obtained from all participants?	☐	☐
Does the research involve deception of participants?	☐	☐
Will personally identifiable data be collected?	☐	☐
Does the research involve animals?	☐	☐
Does the research involve biological materials or hazardous substances?	☐	☐
Could the research cause physical, psychological or social harm to participants?	☐	☐
Does the research have external funding with conditions attached?	☐	☐
Have any conflicts of interest been declared?	☐	☐
Has a Data Management Plan been prepared, addressing storage, security and retention (Section 12.4-12.5)?	☐	☐
Has the intended publication venue been checked against predatory journal indicators (Section 12.7)?	☐	☐
Has an authorship agreement been discussed and documented among all contributors, including students and supervisors (Section 12.6)?	☐	☐
Will AI tools be used in the research (e.g., for analysis or writing)? If so, has the disclosure requirement in Section 14.5 been noted?	☐	☐

Brief Description of Research Methodology and Ethical Safeguards:

Signature Designation

Name (Block Letters) Date

SUPERVISOR ENDORSEMENT (for student research):

I confirm that I have reviewed this application and am satisfied that appropriate ethical safeguards are in place.

Signature Designation

Name (Block Letters) Date

FOR IREC USE ONLY:

IREC Reference No.	Date Received	Level of Review	Decision	Conditions
		☐ Exempt / ☐ Expedited / ☐ Full	☐ Approved / ☐ Conditional / ☐ Rejected

Signature Designation

Name (Block Letters) Date

BAC EDUCATION GROUP

Brickfields Asia College | IACT College | Reliance College | Veritas University College | UNIMY

ETHICS & INTEGRITY TRAINING COMPLETION RECORD

Form Reference	ETCR-006 \| Version 1.1 (Draft)
Version / Date	01 July 2025
Institution	☐ Brickfields Asia College ☐ IACT College ☐ Reliance College ☐ Veritas University College ☐ UNIMY

This form is used to record completion of mandatory ethics and integrity training where such training is not automatically logged by the LMS/HR system (e.g., in-person sessions, workshops conducted for a cohort). One form may be used per session/cohort.

SECTION A: SESSION DETAILS

Type of Training: ☐ Staff Induction ☐ Staff Annual Refresher ☐ Student Orientation ☐ Academic Integrity Certification ☐ Other Date of Session: ____________________________________________________________ Facilitator / Trainer Name: ____________________________________________________________ Institution / Department / Programme:

____________________________________________________________ Topics Covered: (refer to Section 21.1-21.4 for required content)

SECTION B: ATTENDANCE RECORD

Name	Staff ID / Student ID	Designation / Programme	Signature	Completion Confirmed (Y/N)

SECTION C: SUBMISSION

This completed form shall be submitted to the HR Department (for staff) or Academic Affairs / Programme Office (for students) within five (5) working days of the session, for entry into the training completion record and onward reporting to the KPI dashboard (Section 20).

Signature Designation

Name (Block Letters) Date

BAC EDUCATION GROUP

Brickfields Asia College | IACT College | Reliance College | Veritas University College | UNIMY

ANNUAL ETHICS KPI & PERFORMANCE REPORT

Form Reference	AEKR-007 \| Version 1.1 (Draft)
Version / Date	01 July 2025
Institution	☐ Brickfields Asia College ☐ IACT College ☐ Reliance College ☐ Veritas University College ☐ UNIMY

This form shall be completed by each Institution’s IEC Secretary and submitted to the GEIC Secretary by 31 January each year, covering the preceding calendar year. The consolidated Group-level data forms the basis of the Annual Ethics Report (Section 22).

SECTION A: INSTITUTION DETAILS

Institution Name: ____________________________________________________________ Reporting Period: 1 January ________ to 31 December ________ Prepared By (IEC Secretary): ____________________________________________________________ Date of Submission: ____________________________________________________________

SECTION B: ETHICS COMPLAINTS AND CASES (Section 20.2)

KPI	This Year	Prior Year	Target / Benchmark	Commentary
Ethics complaints received (total)			Trend monitored
— of which: Academic Integrity
— of which: Harassment / Discrimination
— of which: Conflict of Interest
— of which: Human Rights & Inclusion (Section 3)
— of which: AI Ethics Concerns (Section 14.7)
— of which: Other
Ethics complaints resolved within timeline (%)			>= 90%
Academic misconduct cases (total, AIIR-003)			Trend monitored
Whistleblower reports received			Trend monitored
— of which: substantiated

SECTION C: RESEARCH ETHICS & INTEGRITY (Section 12, 20.2)

KPI	This Year	Prior Year	Target / Benchmark	Commentary
REAA-005 applications received
REAA-005 applications approved
Average IREC turnaround time (working days)			<= 30 days
Retractions / corrections / expressions of concern			Target: 0
Predatory-publication findings (Section 12.7)			Target: 0

SECTION D: TRAINING AND AWARENESS (Section 21)

KPI	This Year (%)	Prior Year (%)	Target	Commentary
Staff induction training completion rate			100% within 30 days
Staff annual refresher training completion rate			100%
Student ethics orientation completion rate (new intake)			100%
Academic Integrity Certification completion rate (new intake)			100%
Conflict of Interest annual declaration completion rate			100% by 31 Jan

SECTION E: HUMAN RIGHTS, INCLUSION, ESG & SUSTAINABILITY (Sections 3, 27)

Briefly describe key initiatives, progress, and any issues arising during the reporting period:

SECTION F: DECLARATION

I declare that the information in this Annual Ethics KPI & Performance Report is true and accurate to the best of my knowledge.

Signature Designation

Name (Block Letters) Date

FOR GEIC USE ONLY — Reviewed and Consolidated By:

Signature Designation

Name (Block Letters) Date

POLICY APPROVAL AND SIGN-OFF

This Ethics, Integrity and Responsible Conduct Policy was reviewed, approved and adopted by the Board of Directors of BAC Education Group on the date indicated below.

Institution	Approving Authority	Signature	Date
BAC Education Group (Group Level)	Board of Directors
Brickfields Asia College	Board of Governors / Principal
IACT College	Board of Governors / Principal
Reliance College	Board of Governors / Principal
Veritas University College	Board of Governors / Vice Chancellor
UNIMY	Board of Governors / Vice Chancellor

Policy Review Commitment

This Policy shall be reviewed every two (2) years, or earlier in the event of material changes in applicable law, regulatory requirements, or institutional circumstances. The GEIC is responsible for coordinating the review and recommending updates to the Board. Given the introduction of the Ethics Performance Monitoring framework (Section 20), the GEIC shall additionally consider, as part of each Annual Ethics Report (Section 22), whether any in-year amendment to this Policy is warranted based on KPI trends or external developments (e.g., updated QS, MQA or AIGE guidance).

Next Scheduled Review: 1 June 2027

ETHICS POLICY

DOCUMENT CONTROL

DOCUMENT DISTRIBUTION

TABLE OF CONTENTS

PART A: PRELIMINARY

PART B: ETHICAL STANDARDS AND OBLIGATIONS

PART C: GOVERNANCE, REPORTING AND ENFORCEMENT

PART D: SPECIFIC POLICIES

PART E: FORMS AND SOPs

PART A: PRELIMINARY

1. PREAMBLE AND INTRODUCTION

2. VISION, MISSION AND CORE ETHICAL VALUES

2.1 Vision

2.2 Mission

2.3 Core Ethical Values (BAC GROUP-ETHICS)

3. HUMAN RIGHTS, EQUITY AND INCLUSION

3.1 Policy Statement

3.2 Commitments

3.3 Implementation

4. SCOPE AND APPLICATION

5. DEFINITIONS

6. LEGISLATIVE AND REGULATORY FRAMEWORK

PART B: ETHICAL STANDARDS AND OBLIGATIONS

7. CODE OF ETHICS FOR ACADEMIC STAFF

7.1 Responsibilities Toward Students

7.2 Responsibilities Toward the Profession

7.3 Responsibilities Toward Colleagues

7.4 Responsibilities Toward Parents, Community and Nation

7.5 Assessment and Grading Ethics

8. CODE OF ETHICS FOR NON-ACADEMIC STAFF

8.1 Core Obligations

8.2 Admissions and Enrolment Staff

8.3 Finance and Procurement Staff

9. CODE OF ETHICS FOR STUDENTS

9.1 Academic Conduct

9.2 Behaviour and Conduct

9.3 Use of Institutional Resources

9.4 Community Responsibilities

10. CODE OF ETHICS FOR MANAGEMENT AND LEADERSHIP

10.1 Board of Directors / Board of Governors

10.2 Senior Management (Vice Chancellor, Principal, Chief Executive and equivalent)

10.3 Heads of Department / Programme Coordinators

11. ACADEMIC INTEGRITY

11.1 Definition and Scope

11.2 AI-Generated Content

11.3 Responsibilities

12. RESEARCH ETHICS AND INTEGRITY

12.1 Principles of Ethical Research

12.2 Research Ethics Review

12.3 Prohibited Research Conduct

12.4 Open Science and Data Management

12.5 Research Data Retention

12.6 Responsible Authorship

12.7 Predatory Journals and Conferences

12.8 Publication Ethics

13. CONFLICT OF INTEREST

13.1 Definition

13.2 Examples of Conflicts of Interest

13.3 Disclosure and Management

14. AI ETHICS AND RESPONSIBLE TECHNOLOGY

14.1 Policy Statement

14.2 Responsible AI Principles

14.3 Ethical Use in Teaching

14.4 Ethical Use in Assessment

14.5 Ethical Use in Research

14.6 Governance and Cross-Reference

14.7 Reporting Concerns

PART C: GOVERNANCE, REPORTING AND ENFORCEMENT

15. ETHICS GOVERNANCE STRUCTURE

15.1 Group Ethics and Integrity Committee (GEIC)

15.2 Institutional Ethics Committee (IEC)

16. REPORTING MECHANISM AND WHISTLEBLOWING

16.1 How to Make a Report

16.2 Whistleblower Protections

17. INVESTIGATION PROCEDURES

18. DISCIPLINARY ACTION AND SANCTIONS

18.1 Range of Sanctions

18.2 Students

18.3 Right of Appeal

19. PROTECTION AGAINST VICTIMISATION