Institutional Policy

ANTI-FRAUD, BRIBERY,
AND CORRUPTION POLICY

Risks and Audits Division

December 2014 – Updated version in September 2021

IP 04
Institutional Policy

Anti-fraud, bribery,
and corruption policy

1. FRAUD, BRIBERY AND CORRUPTION: OBSTRUCTIONS

TO INTERNATIONAL AID 3
1.1 Definition of fraud, bribery and corruption Anti-fraud,
1.2 Their impact bribery, and
corruption policy
2. HUMANITY & INCLUSION AND THE FIGHT AGAINST FRAUD,
BRIBERY, AND CORRUPTION 4 2
2.1 Principles
2.2 A pragmatic approach
2.3 Scope of the policy

3. ANTI-FRAUD, BRIBERY AND CORRUPTION MEASURES 6

3.1 Promoting an anti-fraud, bribery and corruption culture
3.2 Anticipation, prevention and dissuasion
3.3. Due diligence and detection
3.4 Internal controls and audits
3.5 Reporting of suspicions and Whistleblowing
3.6 Internal investigations and case management
3.7. Information of third parties
3.8 Reporting and learning from experience

4. POLICY IMPLEMENTATION AND MONITORING 4

4.1 Engagement by senior management
4.2 General mobilisation

5. VALIDATION AND DISSEMINATION OF THIS POLICY 5

I.
Fraud, bribery and
corruption: Obstructions
to international aid
1.1 Definition of fraud, financial payment, payment in kind, or
bribery and corruption other advantage. Cases of bribery may
therefore include the acts of soliciting,
When implementing its mission and promising, offering, giving or accepting
activities, Humanity & Inclusion (HI) must an undue pecuniary or other advantage,
guard against the misappropriation of affecting the proper performance of duties
its financial or material resources, and in and constituting an act that is legally and
particular against the risk of fraud, bribery ethically reprehensible.
and corruption.
Fraud pertains to acts which aim to obtain 1.2 Their impact
an undue material or moral advantage by
deliberately circumventing internal rules, 1.2.1
contract rules or laws to the detriment of HI
Fraud and various forms of bribery and
or a third party: individuals, communities,
corruption are a world-wide phenomenon
organisations, corporations or institutions. Anti-fraud,
found in all sectors of society. They
Bribery and corruption, associated with bribery, and
pose serious problems for international
other non-ethical conduct, cover a range of corruption policy
cooperation programmes, whether
practices including:
multilateral or bilateral and in both
development and humanitarian aid settings. 3
c onflicts of interest;
fraudulent commissions;
1.2.2
illicit gifts and invitations;
extortion, theft or misappropriation of Fighting fraud, bribery and corruption at
materials or funds; national and international levels is primarily
facilitation payments; the responsibility of local and international
money laundering. authorities, including international
cooperation agencies and donors.
As well as:
abuse of power; 1.2.3
nepotism and favouritism. Conscious of the risks and issues affecting
their resources, image, interventions and
Whilst fraud may be committed unilaterally the effectiveness of their actions in support
by an individual or group of individuals, their beneficiaries, non-governmental
bribery requires a form of transaction organisations must tackle these phenomena
with compensation in the form of a at their level.
II.
Humanity & Inclusion
and the fight against
fraud, bribery,
and corruption
2.1 Principles its programmes’ resources from being
misappropriated or instrumentalised to the
Preamble benefit of armed groups or military forces,
Assuming its responsibilities as a non- regardless of their status or motivations.
governmental organisation engaged in
international action; 2.1.4
Concerned by the professional ethics in HI will not tolerate any form of influence-
this sector; peddling with local, national or international
Working continuously to ensure that best public authorities or with private bodies,
practices are applied to its operations and whatever the country and activity concerned.
activities;
HI takes all possible measures to prevent 2.1.5
the risk of misappropriation, inappropriate HI cannot carry the whole burden and
use of, or loss of the resources entrusted to it responsibility for preventing and combating Anti-fraud,
for the implementation of its missions. fraud, bribery and corruption in the bribery, and
environment in which it operates. However, corruption policy
2.1.1 with regard to its own activities, it will take
HI will not tolerate any form of fraud, bribery all appropriate measures in accordance with 4
or corruption in the conduct of its activities its prerogatives and means, with priority
and has introduced measures to reduce given to the personal safety and security of
the risks and consequences. In application its staff.
of a principle of “zero tolerance”, context-
appropriate actions will be taken in response 2.1.6
to any suspected or confirmed incidents. Furthermore, in its efforts to fight fraud,
bribery and corruption, HI will take care
2.1.2 not to encourage a climate of suspicion and
HI’s anti-fraud, bribery and corruption mistrust.
measures are adapted to the different
categories of prejudice that acts of fraud and 2.2 A pragmatic approach
bribery cause:
first and foremost to its staff; 2.2.1
to the beneficiaries of its projects (should HI adopts a pragmatic approach to
access to services or assistance be preventing and fighting fraud, bribery and
reduced or disrupted); corruption, based on an analysis which takes
and to the organisation and financial into account:
equilibrium of its programmes. risks specific to each of the countries in
which HI works or has offices;
2.1.3 risks inherent in each function/ profession
At the operational level, in situations exercised by its staff;
of political violence or armed conflict, risks related to each sector of activity in
HI will increase its vigilance to prevent its intervention setting.
2.2.2  ny person or associated or intermediary
a
These risks are monitored using internal body employed by HI and acting on its
tools and mechanisms which cross-reference behalf.
data published by specialised bodies (such
as Transparency International) with incidents Consequently, HI ensures that they are
recorded by HI’s own services1. aware of the existence of this policy and its
implications.
2.2.3
This risk monitoring enables HI to focus its 2.3.2
anti-fraud, bribery and corruption actions Operating partners (organisations and
on those countries, staff and beneficiaries institutions)
most exposed to the risk of such incidents. HI will take all the measures required by
Priorities are then determined according this policy with regard to information, risk
to the size of the budget, the value of the management, support and monitoring in its
resources invested per country, programme relations with its operating partners which,
and activity and the level of reputational risk. while not acting on HI’s behalf, interact with
it within the framework of a partnership
2.2.4 agreement.
HI’s anti-fraud, bribery and corruption
measures2 cover, in particular: 2.3.3
staff recruitment and training, Companies and suppliers
project development, HI will take all the necessary information
risk assessment, and risk management measures with its Anti-fraud,
management and internal control, suppliers, as provided for in the contract bribery, and
handling reported and confirmed cases, signed with these suppliers3. corruption policy
and collaboration with other organisations
in this domain. 2.3.4
5
Potential sanctions
2.2.5 In the event of non-compliance with the
These measures are monitored and provisions set forth in this policy, and
evaluated by in-house bodies which will depending on the gravity of the situation,
apply all necessary corrective measures in HI reserves the right to take disciplinary
a timely manner and ensure any necessary measures, impose penalties, terminate
support, or even protection, for anyone contracts and take legal action with regard
who connected with the exposure of to those individuals or organisations found
reprehensible acts. to be responsible of wrongdoing.

2.3 Scope of the policy

2.3.1
Members and staff
This policy and its provisions apply, after any
necessary adaptations, to:
HI’s permanent members and staff
whatever their status (trustees,
employees and volunteers);

1. Existing and future tools will be regularly adjusted to the needs and reality of the situation.
2. These anti-fraud, bribery and corruption measures may overlap with other of HI’s policies and provisions, such as the
Protection of beneficiaries from sexual exploitation, abuse and harassment (October 2011, Updated version in 2019),
and the Logistics management, HI policy, 2018.
3. Notably, acceptance of the conditions in HI’s guidelines on good commercial practices for companies submitting a tender.
III.
Anti-fraud, bribery
and corruption measures
Responsibility for the implementation of acts of fraud or bribery. They are specifically
this policy, via the mobilisation of staff and responsible for identifying the type and level
the application of measures for preventing of risk to which our activities and resources
and fighting fraud, bribery and corruption are exposed and also have managerial
lies primarily with the managers at head responsibility for internal control.
office, in the different entities of the HI
Organisation and on its programmes. 3.2.3
Managers are advised on these matters by
3.1 Promoting an anti-fraud, bribery and the support services specialized in these
corruption culture areas.
As such, they may receive advice (on risky
3.1.1 activities or procedures, or on particularly
HI’s statutes, mission and strategy, as well exposed areas). They can obtain advice
as its operating rules and internal control on the implementation of information,
procedures, reinforced by this anti-fraud, prevention, control and protection measures.
bribery and corruption policy are the main All these actions, in addition to reducing the
reference documents for HI members. number of incidents and their severity, have Anti-fraud,
a dissuasive character. This, insofar that the bribery, and
3.1.2 existing system is known and that sanctions corruption policy
HI regularly delivers awareness-raising, will be applied in case of misconduct.
training and information initiatives for its
members and personnel at the Head Offices 6
3.3. Due diligence and detection
of the entities in the HI network, and on its
field operation countries. 3.3.1
As a precaution, HI performs due diligence
3.1.3 on applicants, partner organizations and
In particular, HI makes constant efforts to suppliers with whom it contracts, in order to
sensitive managers and supervisors in order to gain an insight into their status with respect
avoid any potential or actual conflict of interest to the law.
between their private interests and those of HI.
3.3.2
3.2 Anticipation, prevention and dissuasion These verification and detection measures,
made to ensure that HI does not enter into
3.2.1 contracts with persons or entities subject to
As a measure of both transparency and prosecution or sanctions, are carried out in
prevention, HI’s managers and staff are invited strict compliance with the law.
to draw up annually a declaration on conflicts
of interest. The modalities for the establishment 3.4 Internal controls and audits
and collection of declarations are specified
in : Conflicts of interest: Directive for the 3.4.1
implementation of declarations. The implementation of checks and
verification measures by managers are
3.2.2 an integral part of their internal control
HI’s managers at all levels are responsible responsibilities. These measures are decided
for guaranteeing management practices as part of each division’s internal planning
that effectively limit opportunities to commit process.
3.4.2 corruption. This handbook is for the sole
Furthermore, internal audits are decided by use of management staff or other qualified
the federal management bodies in one of persons tasked with processing these cases.
three ways:
as part of the annual audit plan, 3.6.2
chosen randomly, The purpose of internal investigations is to
organised in response to an alert. verify the existence of breaches or deliberate
violations of our internal policies and
3.4.3 guidelines and, where appropriate, to
The reports and recommendations are establish individual responsibilites. The
analysed with a view to assisting the entities report, which is always confidential, is
audited and, more generally the organisation intended for managers in positions of
as a whole. authority and responsibility. The findings of
the report enable managers to choose the
N.B.: Internal control (which aims to verify appropriate measures, including, where the
whether rules are respected) and internal misconduct is proven, to decide on sanctions
auditing (which seeks to assess the level of to be applied or legal proceedings to be
risk control) should not be mistaken with initiated.
internal investigations (see § 3.6).
3.7 Information of third parties
3.5 Reporting of suspicions and
Whistleblowing 3.7.1
In certain circumstances, determined by legal Anti-fraud,
3.5.1 or contractual provisions, HI may be required bribery, and
HI’s members and personnel are required to transmit information relating to incidents corruption policy
to report any suspected cases of fraud, of fraud, under conditions of security and
bribery or corruption, and may do so safely confidentiality.
7
and confidentially in accordance with the
organisation’s guidelines on reporting and 3.7.2
whistleblowing. These conditions notably These notifications to the relevant bodies
set out forth the protection offered to people and donors concerned, are governed by a
using the whistleblowing mechanism. specific HI procedure. They are subject to
approval by HI’s management and comply
3.5.2 with regulations relating to the protection of
Reporting systems adapted to the personal data.
different situations encountered are also
made available to beneficiaries, partner 3.8 Reporting and learning from experience
organisations and suppliers.
All cases dealt with are recorded and a
N.B.: For reporting and whistleblowing report is drawn up for the purposes of
mechanisms see HI’s Institutional Directive analysis. These reports are available for
on Reporting suspicions on fraud and abuse. use, by the appropriate divisions within the
organisation and by relevant bodies such as
3.6 Internal investigations and case the Risk Management Committee and the
management Audit Committee.

3.6.1
Managers are provided with specific
guidelines for use when investigating
or handling cases of fraud, bribery or
IV. V.
Policy implementation Validation and
and monitoring dissemination of this
policy
To assist its personnel with the
implementation and monitoring of this
This version of the anti-fraud, bribery and
policy, HI has put a number of coordination
corruption policy cancels and replaces the
mechanisms and initiatives in place.
version adopted in 2012 and the revised
versions in 2014 and 2019.
4.1 Engagement by senior management
This document is for use by HI’s federal
network, Federation and national
This policy will be coordinated, monitored,
associations, in its head office services and in
assessed and updated at the most senior
the field.
levels of the organisation:
It is not for public distribution, but may be
Executive Division and the Directorate by
communicated to bodies and institutions
delegation of authority from the Board of
in accordance with the information and
Trustees.
management measures set out in the
The policy and its implementation will
chapter “2.3: Scope of this policy”.
be overseen by an Audit Committee
reporting to the Board of Trustees.
Anti-fraud,
4.2 General mobilisation bribery, and
corruption policy
Policy coordination requires the mobilisation
of all entities and divisions involved in: 8
carrying out risk evaluation and internal
controls
implementing and managing programmes
and support services
coordinating and enforcing the different
anti-fraud, bribery and corruption
measures
the management of whistleblowing
mechanisms and internal investigations ;
managing risk monitoring tools and
incidents relating to cases of fraud,
bribery or corruption
introducing measures to support, guide,
and ensure HI’s personnel are capable
of dealing with issues relating to fraud,
bribery and corruption control within
the framework established by the
organisation
the procedures for notifying agencies,
institutions and donors concerned.
This policy has been developed in
conjunction with other institutional
policies and directives, including:

 onflicts of interest.
C
Directive for the establishment and use
of declarations, HI, 2020
Gifts and hospitality: Rules and
decision-making aid, HI 2019.
Reporting suspicions on fraud and
abuse, HI, 2018
Code of conduct: Integrity Code of
Conduct: Integrity, Prevention of abuse
and safeguarding, HI, 2018, updated in
2021

These documents are

available from our intranet
platform HInside.
Anti-fraud,
bribery, and
corruption policy

9
Anti-fraud, bribery,
and corruption policy

This document outlines HI’s approach to

preventing and fighting fraud, bribery and
corruption. It contains a policy framework,
objectives and implementation measures.

Humanity & Inclusion

138 avenue des Frères Lumière
CS 78378 69371 Lyon CEDEX 08 France

[email protected]