ANTI-FRAUD POLICY

1.1 POLICY STATEMENT
Civil Development Organization –CDO has a “zero tolerance” policy towards fraud, bribery Civil Development Organization –CDO has a “zero tolerance” policy towards fraud, bribery, and corrupt practices.
All CDO employees regardless of the position, ethnicity, and race, partners and vendors have a duty to protect the assets of CDO and to comply with relevant laws of the below anti-fraud policies.

2 2.1 PRINCIPLES
CDO’s policy on Fraud, Bribery and Corruption is guided by the principles of:
Integrity: CDO will act in a principled and honest fashion.
Legitimacy: CDO will abide by all applicable laws relating to fraud, bribery and corruption.
Timeliness: CDO staff will report suspicions of fraud, bribery or corruption in a timely manner.
Fairness: CDO will investigate allegations of fraud, bribery or corruption in an even-handed way.

2.1.2
CDO maintains systems and procedures to ensure that the risks of fraud, bribery and corrupt practices are minimized and that any incidents are detected, investigated, reported and dealt with effectively where they do occur.

2.1.3
Where fraud, bribery or corrupt practices are detected, CDO will investigate and take appropriate action against staff, consultants, volunteers, partners, vendors and any other party or individuals

2.1.4
CDO staff, consultants, contractors, interns and volunteers must immediately report any suspicion of fraud, bribery or corrupt practices to the Country Director (if at country office), to the Regional Director (if at regional office) or to a member of the senior leadership team (if at the center).
If they do not feel able to report directly to the General Director, staff can report to their line manager or to the email address of cdo.headoffice@yahoo.com

2.1.5
Failure to report fraud, bribery or corruption will be treated as a serious issue and may result in disciplinary measures being taken.

2.1.6
Attempted fraud, bribery or corruption will be treated with the same seriousness as actual fraud, bribery or corruption under this policy.

2.1.8
Partners and suppliers must report to CDO and take action against fraud, bribery or corruption occurring in their organization and must immediately report to their contact at CDO (or the relevant CDO Country Director) any suspicion of fraud, bribery or corruption within CDO.

Word/Term
Definition
“Bribery” or “corrupt practices” or “corruption”
Offering, giving, receiving or soliciting a financial or other advantage in connection with the performance of a position of trust or a function that is expected to be performed impartially or in good faith.
Behavior which amounts to bribery and corrupt practices includes but is not limited to:

Paying or offering a bribe: where an individual improperly offers, gives or promises any form of material benefit or other advantage, whether in cash or in kind, to another person in order to influence their conduct in any way.

Receiving or requesting a bribe: where an individual improperly requests, agrees to receive or accepts any form of material benefit or other advantage, whether in cash or in kind, which influences or is designed to influence his or her conduct in any way.

Receiving a so-called ‘graft’ or ‘facilitation’ payment: where an individual improperly receives something of value from another party for performing a service or other action that they were required by their employment to do anyway. For example: where a member of staff at a partner refuses to issue the required travel authorizations without a personal payment also being made.

Nepotism or patronage: where an individual improperly uses their employment to favor or materially benefit friends, relatives or other associates in some way. For example, through the awarding of contracts, jobs or other material advantages.

Embezzlement: where an individual improperly uses funds, property, resources or other assets that belong to CDO or a connected organization or individual. For example, a member of staff using building contractors who have been employed to work on a CDO project to work on their own personal property.

Receiving a so-called ‘kick-back’ payment: where an individual improperly receives a share of funds or a commission from a supplier as a result of their involvement in a corrupt bid or tender process.

Collusion– where an individual improperly colludes with others to circumvent, undermine or otherwise ignore CDO’s rules, policies or guidance. For example, where an individual tries to fix the level of a tender in order to bring it below a certain threshold which has been set by CDO.
Abuse of a position of trust– where an individual improperly uses their position within CDO or a connected organization to materially benefit themselves or any other party. For example, an individual intentionally accessing confidential material they are not entitled to or passing confidential information (such as the contents of a tender bid) to a third party.

“Fraud”
An act of deception intended for personal gain or to cause loss to another party (even if no such gain or loss is in fact caused). Behavior which amounts to fraud includes but is not limited to:

False invoicing: where an individual knowingly creates or uses invoices that are false in any way.
Expenses fraud: where an individual dishonestly uses the expenses system to pay money or other benefits that the recipient is not entitled to.

Procurement fraud: where an individual engages in any dishonest behavior relating to procurement or tendering process, e.g. falsely created bids or quotes.

Supply chain fraud: where an individual misdirects or steals goods, forges stock records, or creates fictitious companies through which to channel payments.

Payroll fraud: where an individual dishonestly manipulates the payroll system to make unauthorized payments to him or herself or another. For example, by creating ‘ghost’ employees or dishonestly increasing one’s own salary.

Tax or duty evasion: where an individual knowingly avoids payment of a tax or other duty that he or she is aware should be paid.

False accounting: where an individual deliberately enters false or misleading information into any form of accounting or financial record.

Forgery: where an individual dishonestly creates or alters a document so that the information contained in it is incorrect or in any way misleading.

Bank or cheque fraud: where an individual dishonestly manipulates any banking system or record (such as a cheque, bank statement or electronic transfer).

Brand fraud: where an individual dishonestly uses CDO’ name, branding or documentation for unauthorized or illegitimate ends.

Conflict of interest: where an individual knowingly has an undisclosed business interest in an entity involved in a commercial relationship with CDO.

Theft: where an individual dishonestly takes or appropriates any item of property that belongs to another.
ACKNOWLEDGEMENT OF RECEIPT OF ANTI-BRIBERY AND ANTI-CORRUPTION POLICY
I affirm that I have read and understood the CDO Anti-Fraud policy.