SF ANTI-CORRUPTION POLICY & PROCEDURES
Contents
Contents ................................................................................................................................................................ 1 Introduction ........................................................................................................................................................... 2 1.
The policy aims to: ................................................................................................................................... 2
2.
Scope ........................................................................................................................................................ 2
3.
Policy Statement ...................................................................................................................................... 2
4.
Definition of Corruption and Fraud .......................................................................................................... 2
5.
Responsibilities......................................................................................................................................... 3
6.
Point of contact for allegation of integrity violation ................................................................................ 3
7.
International laws and regulations .......................................................................................................... 4
8.
Procedures for compliance ...................................................................................................................... 4
9.
Reporting suspected cases ....................................................................................................................... 5
10.
Independent channel ............................................................................................................................... 5
11.
Management of suspected and confirmed cases .................................................................................... 5
12.
Compliance and Penalties ........................................................................................................................ 6
13.
Training..................................................................................................................................................... 6
14.
Periodic Audits ......................................................................................................................................... 6
Policy Approval ...................................................................................................................................................... 8 References ............................................................................................................................................................. 8
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Introduction Strømme Foundation (SF) has a zero tolerance policy towards corruption . The purpose of this policy is to establish a supporting mechanism to SF’s anti-corruption program, and set forth the standards and procedures to be followed by Strømme Foundation’s employees at the head office, regional offices, apexes, and implementing partners to prevent corruption and improper exchange in the conduct of business across all Strømme Foundation’s locations worldwide. This policy applies to, but is not limited to, staff of SF in Head Office, Regional Offices and all subsidiaries of SF, partners, FK participants, consultants, contractors, donors, and volunteers including Act Now students.
1. The policy aims to:
Ensure that financial and other resources are used solely for the intended purposes. Promote a culture of honesty and openness among the staff and management of SF. Ensure that our procedures and policy are in line with UK Bribery Act, instruction from Norwegian government, other donor government policies and other applicable stakeholders. Ensure that vulnerable populations are not disadvantaged or exploited by staff members or their associates who commit fraudulent and corrupt acts; and Assure members of staff and target populations that they can safely and confidently raise and report all serious concerns about unethical conduct, suspected fraud and corruption
2. Scope This Policy applies to all SF employees (full time, part time, temporary and casual), and also to SF implementing partners, subsidiary companies, and those who access funds from SF.
3. Policy Statement Unless otherwise expressly permitted by or approved in writing under this Policy and Procedures, - no SF board member, employee, any of its subsidiaries, or any third party acting on behalf of SF shall make, provide, offer or authorize any payment, gift of any kind or anything of value that can be constituted as a bribe, directly or indirectly, to any official or employee of any national, state, provincial or local government or any government owned or controlled agency or entity.
4. Definition of Corruption and Fraud Corruption in broadly defined as the abuse of entrusted power for private gain. There are many different forms of corruption but they can be broadly described as follows:
Any action or omission, including misrepresentation, that knowingly or recklessly misleads, or attempts to mislead, a party to obtain a financial or other benefit or to avoid an obligation. The offering, giving, accepting or soliciting of money, a gift or other advantage as an inducement to do something that is illegal or a breach of trust in the course of carrying out an organisationsactivities. Misappropriation of funds, use of funds for purposes other than designated or for unauthorised/unbudgeted or private purposes.
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Nepotism, patronage or preferential treatment of close friends or family not based on objective merit. Financial misconduct, including criminal acts such as theft of cash and false accounting thereof. Abuse of resources which belong to SF and those provided by, or purchased using funds raised by SF. Abuse of resources can include theft and computer crimes where a computer or network is the source, tool, target, or place of a crime (e.g., unauthorized access, suppression of data, electronic fraud, etc). Use of improper means, such as bribery, kickbacks or so-called ‘facilitation’ payments, by someone to induce another person to act or to refrain from acting in the exercise of her/his duties, in order to obtain or retain an undue advantage. Threatening or actual illegal actions such as personal injury or damage to property, in order to obtain an undue advantage or to avoid an obligation. Collusion in improper procurement or contracting activities. Any attempts to suppress or conceal any of the above.
5. Responsibilities All Employees Read, understand, and follow the articulated policy and procedures. Complete required anti-corruption induction or training. Communicate requirements of policy to external partners and counterparts. Affirm/certify that they have read and follow the anti-corruption policy and procedures. Read, understand and sign the code of conduct. Leadership Ensure dissemination of the policy and procedures to all offices, partners, and subsidiaries. Ensure employees and partners follow policy and procedures, and are employed based on due diligence. Periodic risk assessments reviews & updates by the appropriate managers. Ensure due diligence in the planning, decision, and implementing of programs. In-depth /regular training to strengthen in-house expertise on identifying and managing corruption risks. Update the policy and procedures as necessary. Approve and/or disapprove proposed transactions and/or partners. Board Hold the administration accountable through reviewing reported incidents and promote continued transparency. The board of directors approves the anti- corruption policy. Board members have received written guidance on their responsibilities related to the anticorruption policy, including the expectations for their own integrity
6. Point of contact for allegation of integrity violation Immediate supervisor or in the event of conflict of interest, the intranet or internet channel should be used.
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7. International laws and regulations Acts of bribe, fraud, and corruption are criminal acts and punishable by law. This includes also influence peddling if one demands, receives or accepts offer of an advantage that affect management of one’s position or mission.
8. Procedures for compliance
To ensure compliance with the Anti-Corruption Policy, the following rules have been established to provide guidance for all SF board members, employees, partners, subsidiaries, or any entity acting on behalf of SF and its subsidiaries:
No payment, gift, or anything of value may be promised, offered and/or made to any governmental or non-governmental entity, either directly or indirectly such as through a third party, except as expressly permitted in this policy.
A gift may be provided, if and only it is a promotional gift of modest value and usually bearing the SF logo. Low value gift may be accepted if it is considered culturally offensive if rejected. A written record should be made of all gifts received and where they are of significant value they may be treated as the property of SF and not the individuals.
No facilitating payment may be made by any employee unless it is in response to a medical or safety emergency, i.e. an employee is in imminent jeopardy of serious harm and no other reasonable alternatives are available. Whenever, such a payment is made to ensure the safety of an employee, the circumstances of the payment must be immediately documented in writing and submitted to the relevant director. Further, the purpose and the nature of such payments must be accurately recorded in the books and appropriate record maintained.
No political, charitable contributions or sponsorship can be made directly or indirectly, as this might be used as a subterfuge for bribery.
The selection of new employees, implementing partners, or any agent or, representative or consultant (intermediary) who may be reasonably expected to act on behalf of SF shall be completed with due diligence.
All transactions must be accurately and properly recorded in the books and well documented. Any indication of or suggestion by the implementing partners, subsidiaries, or by other employees to make an improper payment, mischaracterize a transaction in SF’s books and records, or redirect payments to a third party should be promptly reported to the appropriate director or through the intranet channel 810.
False, misleading, incomplete, inaccurate, or artificial entries in the books and records of SF are strictly prohibited. All offices and subsidiaries are required to make and keep books, records and accounts which, in reasonable detail, accurately and fairly reflect the transactions and disposition of the assets of SF. Consequently, all payments and other activities made pursuant to this Policy and implementing procedures must be accurately recorded in SF’s accounts in a timely manner and in reasonable detail. Examples of violations of this policy would include inaccurate employee expense reports which conceal the true purpose funds or the preparation and/or approval of false or misleading invoices from an implementing business partner.
There may be instances where payments will need to be made to protect against loss of life, limb or liberty. These are called payments under duress and as such are permitted under the law, however
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the assumption is these are rare. Any payment or incident such as this must be reported to your line manager as a payment under duress and security procedures will be revised accordingly.
9. Reporting suspected cases Board members, employees, subsidiaries, and implementing partners should report any conduct among partners, regional office/apex or in head office which they believe in good faith to be a violation or apparent violation of this Policy. Reporting of suspected corruption/fraud cases can be done in 2 ways: 1.
Mail: a notice on e-mail can be sent to the department head (if in head office) and the regional director (in the regional offices/apex), with a copy to international director and the financial director (unless there is a suspicion that one of them is involved in which case use the independent intranet channel).
2.
Telephone/meeting face to face: A suspected corruption case can be notified by telephone/conversation with the department head (if in head office) or regional director (if in Regional office/apex). The regional director must immediately inform the PD director/MF director and finance director, (unless there is a suspicion that one of them is involved in which case use the independent intranet channel).
10. Independent channel Independent complaint mechanism: A suspected corruption case can be reported through SF’s websites (Whistleblower). All incoming reports will be handled confidentially and reviewed by an established control committee consisting of at least two and preferably three employees to include an internal controller, employees’ representative and/or HR representative and one other. An external person will be included if needed. The control committee is responsible for ensuring that all reported cases to this channel are followed up by the appropriate manager, they are not responsible for the dealing with the allegation themselves.
Employees with questions about complying with this Policy or an intended course of action are encouraged to consult the finance director or financial control manager before proceeding. No retaliation shall be taken against any employee who reports any suspected violation while acting in good faith. Supervisors or other employees who retaliate against whistle-blowers are in violation of this policy and consequently are subject to disciplinary action up to and including termination. Similarly the whistle blower has responsibility for their own actions and anyone making malicious deliberately false reports will also face disciplinary action
11. Management of suspected and confirmed cases
When corruption or fraud is suspected an internal investigation will be launched by the head office or the regional office. After internal investigation, the regional director, international director and finance director will decide whether a forensic audit is needed. Cases reported to the independent complaint mechanism will be routed to the appropriate manager.
All corruption cases in the head office will be handled by the head office management and the external auditor. If the corruption or fraud concerns the regional office or apex, head office will in close relationship with the regional director, unless he/she is involved, investigate and follow up all related issues.
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If the corruption/fraud concerns a member of staff, the employee is immediately taken out on forced leave while the investigations are being performed. If the suspicions are confirmed, the employee’s contract will be terminated.
In the case of suspected fraud or corruption within the partners, the relevant donors will be informed, the case will be internally documented, and the regional staff are responsible for follow up with the partner. All funding will be immediately suspended and if fraud or corruption is confirmed, appropriate action will be taken to recover the loss, to include legal action if needed. The decision to continue or terminate the partnership will depend on the attitude of the partner organisations management/board and their ability/willingness to deal with perpetrators and strengthen internal controls.
The investigation process should maintain objectivity, impartiality, and fairness and should be conducted with the highest levels of integrity. The investigation should be conducted expeditiously within the constraints of available resources.
Investigative findings shall be based on facts and analysis, which may include reasonable inferences. The circulation of information regarding on-going investigations should be strictly limited to those with a need to know. The identities of parties providing testimony or evidence shall be treated with confidentiality.
Staff are required to cooperate with an investigation and to answer questions and comply with requests for information.
SF may engage external parties to assist in the investigation when that is deemed necessary.
All documentation and information regarding open or closed cases, whether substantiated or unsubstantiated, shall be kept in a secure and confidential manner and shall be retained for at least ten years.
12. Compliance and Penalties Each SF manager and employee is responsible for compliance with and implementation of this Policy and the attached implementing procedures. Failure to comply with this Policy and its procedures will be grounds for disciplinary action up to and including termination. In addition, individuals violating anti-bribery laws may be fined and imprisoned as the result of criminal prosecution.
13. Training Anti-corruption training will be provided to new employees as part of their induction orientation. Employees are required to participate in anti-corruption training on a periodic basis and will be required to certify periodically that they have been informed of any changes to the policy.
14. Periodic Audits
On a periodic basis, compliance with this Anti-Corruption Policy and its required controls will be reviewed and tested. Agreements and relationships with SF employees, implementing partners, and intermediaries interacting with government officials supported by proper documentation: Due diligence reports Pre-engagement review and approval
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  
Incorporation of anti-corruption and anti-bribery assurances in agreements and contracts. Payments to applicable implementing partners and intermediaries are reviewed for reasonableness in terms and for authorization; Bank accounts and petty cashes accounts are regularly reviewed and reconciled.
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Policy Approval
Date: Place: Name:
11.March 2014 Kristiansand SF Board
References -
SF Ethical Guidelines Financial Rules and Regulations Procurement & Investment Policy SF Human Resources Policy SF Partner Selection and Assessment Tool
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