Anti-Fraud Policy & Guidelines for Investigations

Sustainable Development Council (SDC) Anti-Fraud Policy & Guidelines for Investigations

Effective Date: [7 June 2019]

1. Purpose and Introduction: The Sustainable Development Council (SDC) is committed to maintaining the highest standards of integrity, transparency, and ethical conduct. This Anti-Fraud Policy and Guidelines for Investigations articulate SDC’s stance against fraud in all its forms. This policy establishes the framework for preventing, detecting, and responding to fraudulent activities within the organization.

2. Definition of Fraud: For the purposes of this policy, “fraud” is defined as any intentional misrepresentation, deception, or other unethical act that results in an unauthorized benefit or financial loss to SDC. Fraudulent activities may include, but are not limited to, misappropriation of funds, embezzlement, bribery, corruption, kickbacks, and falsification of records.

3. Scope: This policy applies to all SDC employees, interns, fellows, volunteers, representatives (collectively referred to as “SDC Staff”), as well as SDC grantees/awardees, contractors, suppliers, consultants, and their employees, sub-grantees/awardees, and representatives (collectively referred to as “Partners”) engaged by SDC. The policy extends to cover all activities and operations conducted under the auspices of SDC.

4. Key Principles: SDC is guided by the following principles in its commitment to combating fraud:

a. Prevention: Implementing measures to prevent and deter fraudulent activities through robust internal controls, segregation of duties, and awareness programs.

b. Detection: Establishing mechanisms for the timely detection of fraudulent activities, including the encouragement of whistleblowing and reporting mechanisms.

c. Investigation: Conducting thorough and impartial investigations into suspected fraud, ensuring due process and adherence to legal and ethical standards.

d. Response: Taking appropriate disciplinary and legal actions against individuals found guilty of fraud, as well as implementing corrective measures to prevent future occurrences.

5. Responsibilities of SDC Staff and Partners: All SDC Staff and Partners are responsible for:

a. Awareness: Familiarizing themselves with this policy and understanding their role in preventing, detecting, and reporting fraud.

b. Reporting: Promptly reporting any suspicions, concerns, or knowledge of fraudulent activities through established reporting channels.

c. Non-Retaliation: Ensuring that no individual faces retaliation for reporting fraud concerns in good faith.

6. Prevention Measures: SDC commits to implementing the following preventive measures:

a. Internal Controls: Establishing and maintaining robust internal controls to safeguard against fraud.

b. Segregation of Duties: Ensuring a clear segregation of duties to prevent conflicts of interest and opportunities for fraud.

c. Awareness Programs: Conducting regular awareness programs to educate SDC Staff and Partners about the risks of fraud and the importance of ethical conduct.

7. Reporting Mechanisms: SDC has established confidential reporting mechanisms, such as an online Ethics Hotline or phone number, for individuals to report fraud concerns. Reports will be treated confidentially, and appropriate actions will be taken to investigate and address reported incidents.

8. Investigation Procedures: In the event of a suspected fraud, SDC will initiate a thorough and impartial investigation. Investigation procedures will adhere to legal and ethical standards, ensuring due process is afforded to all parties involved.

9. Disciplinary Actions: Individuals found guilty of engaging in fraudulent activities may face disciplinary actions, including but not limited to termination of employment or contractual relationships. Legal actions may be pursued where warranted.

10. Continuous Improvement: SDC is committed to continuously reviewing and improving its Anti-Fraud Policy and Guidelines for Investigations to adapt to evolving challenges and best practices in combating fraud.

Conclusion: SDC affirms its commitment to a fraud-free environment, reinforcing the organization’s dedication to integrity, transparency, and ethical conduct. This policy serves as a cornerstone in fostering a culture that actively prevents, detects, and responds to fraud, thereby safeguarding the resources entrusted to us for sustainable development.

Through collective vigilance and adherence to these principles, SDC aims to uphold its reputation as a trustworthy steward of resources dedicated to the advancement of sustainable development goals.