Anti-Fraud and Corruption Policy

Purpose

The purpose of this policy is to establish and maintain a framework for preventing, detecting, and responding to fraud and corruption within the KALTOOR Foundation. The policy aims to protect the Foundation’s assets, reputation, and operations from fraudulent and corrupt practices.

Scope

The policy applies to all employees, volunteers, board members, contractors, suppliers, and any other individuals or organizations associated with the KALTOOR Foundation.

Definitions

• Fraud: Any deliberate act of deception intended for personal gain or to cause a loss to the Foundation or others, including falsification of records, theft, and embezzlement.
• Corruption: Abuse of power or position for personal gain or advantage, including bribery, kickbacks, and conflicts of interest.

Policy Statements

• The KALTOOR Foundation is committed to preventing, detecting, and addressing fraud and corruption in all its operations.
• All forms of fraud and corruption are strictly prohibited and will be dealt with seriously.
• The Foundation will take appropriate action against anyone involved in fraudulent or corrupt activities, including disciplinary measures and legal action.

Responsibilities

A. Management Responsibilities

• Develop and implement anti-fraud and corruption policies and procedures.
• Ensure that all employees and volunteers are aware of and adhere to the policy.
• Provide training on anti-fraud and corruption measures and promote a culture of integrity and transparency.
• Investigate any suspected or reported incidents of fraud or corruption.

B. Employee and Volunteer Responsibilities

• Adhere to the Foundation’s anti-fraud and corruption policies and procedures.
• Report any suspicions or evidence of fraud or corruption to the designated Fraud and Corruption Officer or through the established reporting mechanisms.
• Cooperate with investigations into suspected fraudulent or corrupt activities.

Prevention Measures

A. Risk Assessment

• Conduct regular risk assessments to identify potential vulnerabilities to fraud and corruption.
• Implement controls and procedures to mitigate identified risks.

B. Internal Controls

• Establish and maintain strong internal controls, including financial controls, segregation of duties, and regular audits.
• Ensure that all financial transactions are recorded accurately and transparently.

C. Policies and Procedures

• Develop and enforce policies and procedures to prevent fraud and corruption, including those related to procurement, financial management, and conflicts of interest.
• Ensure that policies are regularly reviewed and updated.

Reporting and Whistleblowing

A. Reporting Mechanism

• Provide a clear and confidential process for employees, volunteers, and other stakeholders to report suspected fraud or corruption.
• Ensure that reports can be made anonymously if desired.

B. Whistleblower Protection

• Protect individuals who report concerns in good faith from retaliation or discrimination.
• Ensure that whistleblowers are informed about the protection measures in place and the process for handling their reports.

Investigation and Response

A. Investigation Process

• Investigate all reported incidents of fraud and corruption promptly and thoroughly.
• Maintain confidentiality during investigations and protect the rights of all parties involved.
• Document all findings and actions taken during the investigation.

B. Disciplinary Action

• Take appropriate disciplinary action against individuals found to be involved in fraud or corruption, which may include termination of employment or volunteer roles.
• Pursue legal action if necessary to recover losses or hold individuals accountable.

Training and Awareness

• Provide regular training to all employees and volunteers on anti-fraud and corruption policies and procedures.
• Promote a culture of integrity and transparency within the organization.

Monitoring and Review

• Regularly monitor and review the effectiveness of anti-fraud and corruption measures and policies.
• Conduct periodic audits and assessments to identify areas for improvement.
• Update the policy as needed to reflect changes in legislation, best practices, or organizational needs.

Confidentiality and Data Protection

• Ensure that all information related to fraud and corruption investigations is handled confidentially and in compliance with data protection regulations.
• Restrict access to sensitive information to authorized personnel only.

Communication

• Communicate the anti-fraud and corruption policy to all employees, volunteers, and relevant stakeholders.
• Display information about reporting mechanisms and the consequences of fraudulent or corrupt behavior prominently.