The organization requires all staff to act honestly and with integrity to safeguard the organization’s resources and ensure that the resources are properly used for the purposes intended. Fraud and corruption are ever-present threats to an organization that can undermine the organization’s credibility, therefore, must be a concern to all staff members. To ensure that LI-BIRD continues to demonstrate its highest standards of accountability, transparency and legal compliance, it is imperative that clear guidance is provided for addressing the risks of fraud and corruption. This policy statement sets out the specific responsibilities of LI-BIRD employees with regard to the risks of fraud, irregularity, bribery and corruption. This statement demonstrates the commitment of LI-BIRD’s Governing Body – the Executive Board - and Senior Management to promoting a culture of integrity and transparency across LI-BIRD’s mission.

LI-BIRD defines ‘Fraud’ as ‘the intentional distortion of financial statements or other records by person/s in the organization, which is carried out to conceal the misappropriation of assets for gain’;

‘Bribery’ is defined as ‘the offer, promise, giving, demanding or acceptance of an advantage in monetary or other forms of reward for the improper performance of a function or activity; and ‘Corruption’ means ‘the misuse of power for gain’.

Although this policy explicitly refers to fraud, financial mismanagement, bribery and corruption, it also applies to any forms of malpractice that reduce confidence in LI-BIRD and its business services. This policy statement applies to all LI-BIRD employees (full or part-time), interns, advisors, volunteers and members, including Founder and Executive Board members, and to any irregularity or suspected irregularity involving employees as well as consultants, vendors, contractors or any other parties that have a business relationship with LI-BIRD. 

This policy statement should be read in conjunction with LI-BIRD’s other policies, regulations and procedures, especially: (i) LI-BIRD Whistleblower Policy 2018; (ii) LI-BIRD Safeguarding Policy 2019; (iii) LI-BIRD Governance Manual 2018; (iv) LI-BIRD Financial Administration and Regulations 2006 (Revised in 2018); and (v) LI-BIRD Anti-Money Laundering and Combatting Financing Terrorism Policy 2022.

LI-BIRD is committed to preventing fraud and corruption and developing an anti-fraud culture. To achieve this, LI-BIRD will:

• Build the capacity of staff, partners and other stakeholders through adequate orientation on anti-fraud policy and procedures;
• Review and strengthen its systems and procedures and maintain adequate and effective controls to prevent fraud;
• Ensure that if fraud occurs a vigorous and prompt investigation takes place;
• Take appropriate disciplinary and legal action in all cases, where justified; and
• Record and report all discovered cases of fraud.

LI-BIRD takes a zero-tolerance approach to any incidents of fraud, irregularity, bribery and corruption. The following principles will apply in LI-BIRD:

• LI-BIRD staff must have the highest standards of honesty and integrity in the exercise of their duties;
• LI-BIRD will not tolerate fraud and will investigate all instances of suspected fraud by LI-BIRD staff and its partners/sub-grantees or any other parties with a business relationship with LI-BIRD;
• LI-BIRD will take action, including dismissal and/or criminal prosecution, against any member of staff, partners or other parties (with a business relationship with LI-BIRD) defrauding or attempting to defraud; and
• LI-BIRD will seek to recover funds lost through fraud.

LI-BIRD recognizes that the primary responsibility for the prevention and detection of fraud rests with LI-BIRD Senior Management, while the Executive Board will be accountable for ensuring the adequacy and effectiveness of the internal control system designed to counter fraud, and for the rigorous investigation of any such cases.  It is essential that all LI-BIRD staff report any irregularities or suspected irregularities to the LI-BIRD Compliance Manager/Internal Auditor via their Team Leader/Line Manager as they are the first line of defense against fraudulent activity. The Compliance Manager will report the case to the Executive Board via the Senior Management Committee, and will be responsible for initiating the initial investigation. LI-BIRD will provide reasonable protection for those who raise genuine concerns in good faith, in accordance with LI-BIRD’s Safeguarding and Whistleblower policies. The Head of Administration and Finance will be responsible for developing and maintaining adequate and effective controls against fraud, while the Human Resource Manager will enforce LI-BIRD’s anti-fraud policies. In conjunction with the Human Resource Manager, the Compliance Manager will develop an action plan to monitor and track possible fraud cases and draw lessons during the program implementation.

This policy statement will be reviewed annually by LI-BIRD’s Executive Board and Senior Management Committee to ensure its suitability. Where necessary it will be amended, reissued and communicated to all LI-BIRD employees, partners and people/organizations working on LI-BIRD’s behalf.

Date: 20 September 2018