Draft policy 07
Anti-Fraud & Anti-Corruption Policy
The Foundation should prevent, identify and respond to fraud, bribery, theft, falsified records, kickbacks and misuse of humanitarian resources.
Zero private benefit from project fundsFoundation resources should not be diverted for undisclosed personal, family, political, business or other improper benefit.
No bribery or kickbacksNo person acting for the Foundation should offer, request or accept an improper payment, commission, favour or benefit to influence a decision.
Accurate recordsBudgets, invoices, receipts, transaction references, distribution records and reports should not be fabricated, altered or knowingly misrepresented.
Verification before paymentPayments should be supported by proportionate evidence and approval, with heightened scrutiny for cash, unusual payment routes and related parties.
Supplier and partner checksRelevant counterparties should be subject to proportionate identity, conflict and due-diligence checks before significant work or funds are entrusted to them.
Segregation of dutiesWhere practical, initiating, approving, paying and reconciling a transaction should not all be controlled by the same person.
Reporting concernsSuspected fraud or corruption should be reported through the complaints / whistleblowing route or directly to appropriate governance personnel.
Preserve evidenceRelevant documents, communications and transaction records should be preserved when suspected wrongdoing is identified.
No retaliationGood-faith reporting should not result in retaliation, loss of assistance or improper adverse treatment.
ResponseConfirmed or credible serious concerns may require suspension of payments, recovery action, removal of access, partner review and referral to appropriate authorities or professional advisers.
Pre-launch status
Controls before scale.
This policy is an internal control framework and does not replace legal advice, law-enforcement reporting duties or specialist financial investigation.
Material incidents, suspected wrongdoing or legal obligations should be escalated to appropriate qualified or external support rather than handled informally where that would be inadequate.