Anti-Fraud and Anti-Corruption Policy

Aug 16, 2019 · The organisation recognises that the prevention and detection of fraud and corruption is the responsibility of every member of our orga...

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Anti-Fraud and Anti-Corruption Policy

COMDU.IT

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COMDU.IT

400 – 2425 Eglinton Avenue East, Toronto, Ontario M1K 5G8 Canada | [email protected] | www.comdu.it

1.0 Overview comdu.it (the “organisation”) is committed to high ethical standards and transparency in all our work and to remain accountable to all internal and external stakeholders, including beneficiaries, donors, partners, employees, volunteers, managers, and directors. The Anti-Fraud and Anti-Corruption Policy (the “Policy”) outlines the organisation’s approach to the prevention and control of fraud and corruption, including the investigation procedures that will be followed if there are suspicions of fraudulent or corrupt practices. If fraud or corruption is proven, appropriate disciplinary measures and legal action will be taken. The organisation, in accordance with best risk management practice, acknowledges that strong internal prevention mechanisms and controls at all administrative levels and locations in the organisation, are the best methods for preventing fraud and corruption. The organisation is committed to preventing and dealing swiftly and appropriately with fraud and corruption perpetrated and recognises that fraud and corruption prevention and control is not a separate function and needs to be incorporated into all aspects of its activities. Accordingly, the organisation will ensure that there are elements of fraud and corruption prevention and control in all relevant policies, procedures and systems. All comdu.it personnel are responsible for fraud and corruption prevention and control will be made aware of this policy. Adherence will be ensured as applicable.

2.0 Definitions “Fraud” is defined as any intentional act or omission designed to deceive others, resulting in the victim suffering a loss and/or the perpetrator achieving a gain. “Corruption” is defined as the abuse of entrusted power for private gain, including bribery. Fraud and corruption do not necessarily imply immediate financial benefits for the individual(s) committing fraud or corruption, but may cause financial or reputational damages to the organisation. The organisation considers such offenses to be criminal and/or violations of civil law.

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3.0 Elements of Fraud and Corruption In cases of fraud and corruption there are generally three elements which individually can be addressed to prevent the act: • Perceived Opportunity: often a gap in controls, an opportunity that fraud or corruption can be perpetrated without the person committing the fraud and corruption being caught, exposed and/or action taken against them. • Motive: the reason why the person is committing the act of fraud and/or corruption. • Rationalisation: is the justification of the act of fraud or corruption. Rationalisation is not to be confused with the difference between right or wrong. In fact, the perpetrator often knows that it is wrong, but will think the act justified for one reason or another.

4.0 Scope of the Policy The organisation recognises that the prevention and detection of fraud and corruption is the responsibility of every member of our organisation, including directors, staff and volunteers, as well as our overseas partner organisations. As such, it is the responsibility of the administration of the organisation to create an ethical culture encouraging fraud and corruption prevention. The organisation takes a firm position against corruption in any form, and actively works to prevent, avoid and detect all forms of corruption through a set of compliance procedures. It has zero- tolerance for all types of corruption, and acts and reacts promptly when/if corruption occurs. The organisation’s members and volunteers are not allowed to provide for, request or receive anything that can be defined as corruption according to the organisation’s definition of corruption.

5.0 Prevention of Fraud and Corruption 5.1 Workers and Managers • •

All “workers” meaning any volunteer or employee of the organisation, including volunteers, regular employees, new hires, contract, casual, temporary, part-time and student workers; and All “managers,” meaning any of the organisation’s supervisors, managers, members of the Board of Directors, chairs of subcommittees of the Board.

All comdu.it workers and managers must commit to a zero-tolerance towards corruption and the managers must foster an understanding and culture where corruption is not tolerated. Workers are recruited according to strict guidelines that ensure appropriate reference checks are made. Workers and managers must sign a Statement of Commitment as part of their Non-Disclosure Agreement declaring that they understand comdu.it’s organisational values and understand what is expected of them in their role. Similarly, the organisation undergoes an extensive process of due diligence before working with our overseas partner organisations in the project implementation process, which ensures our partner organisations share our values, governance and anti-fraud and anti-corruption policies.

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The organisation is committed to ensuring that worker and managers are provided induction, and remain aware of the Policy. 5.2 Finance The organisation employs an effective financial management program that allows us to record, track and reconcile donation revenue with assigned project funds. Annual budgets are prepared at the start of each financial year and tracked monthly to detect any variance in budget. Budget reviews are undertaken each halfyear. All expenditure has dual authorization and is documented on an authorization form. The organisation additionally undergoes annual internal auditing processes. At least once every year, the accounts of the organisation are examined by an external qualified auditor, who must report to the Board of Directors in accordance with the Canadian Auditing Standard. 5.3 Project Execution The organisation also rigorously monitors the design, implementation, management and results of our overseas projects, as it believes that monitoring and evaluation is a crucial part of determining the success of the projects and partners, and a key part of our measures of success is ensuring fraud or corruption does not occur.

6.0 Handling of Allegations The handling of any allegations of fraud or corruption including investigations and any eventual disciplinary measures shall be in accordance with the Policy. 6.1 Reporting of Fraudulent and Corrupted Practices As per the Policy, workers or managers who have knowledge of an occurrence of fraud or corruption or has reason to suspect that a fraudulent or corrupt act has occurred, have a duty to promptly report any reasonable allegations to the Founding Chair ([email protected]). Should the allegation involve the Founding Chair, it should be reported to the Company Secretary ([email protected]). 6.2 Confidentiality of Information and Identity Protection The organisation is committed to take all appropriate measures to ensure that information reported remains confidential and is only disclosed to authorized individuals and investigators. The organisation will protect the identity of those reporting in good faith any suspicions of fraud and corruption and take appropriate measures to protect them from retaliation. Members who reported in good faith suspicions of fraud or corruption also required to commit not to discuss the matter with anyone other than the person to whom the report is made, unless it was not addressed to the right person in the first place or, as otherwise directed.

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6.3 Security of Data To ensure that all documentation relating to an alleged fraud or corruption is available for review in its original form the organisation is committed to put forward immediate action to prevent the theft, alteration, or destruction of all such documentation. 6.4 Investigation The organisation aims to create a culture that encourages fraud and corruption detection, ensures that whistleblowers are protected, and investigates allegations in a rigorous and impartial manner. Training is provided for staff and volunteers regarding fraud and corruption detection. Our Whistleblowing Policy clearly outlines the mechanism through which employees, volunteers, directors and other representatives of the organisation must report allegations of fraud or corruption, and our staff and volunteers sign a Statement of Commitment declaring their promise to do this. We are committed to ensuring no negative outcomes occur for whistleblowers acting in good faith. Investigations must be completed in a confidential, prompt and professional manner according to established guidelines. If allegations of fraud or corruption are proved to be correct, the organisation is committed to taking disciplinary action in a transparent and fair manner.

7.0 Communicating This Policy This policy is published on the organisation’s website (www.comdu.it) and provided to all employees, volunteers, directors, consultants and other representatives, and local partners.

8.0 External: Legislative and Regulatory Framework • • • •

Organisation for Economic Co-operation and Development’s Convention on Combating Bribery of Foreign Public Officials in International Business Transactions (1999). United Nations Convention against Corruption (2005). Canada’s Corruption of Foreign Public Officials Act, 1998. Canada’s Criminal Code, 1985.

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Document Control Last Reviewed Aug 16, 2019

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Prepared By Janakan Muthukumar

Reviewed By Kumaran Nadesan

Approved by Board of Directors

Next Review Aug 16, 202

COMDU.IT