Fraud and Corruption Policy

1. Goal

Through this policy on fraud/corruption, the Diplomacy Training Program (DTP) aims to:

• provide a clear statement that DTP maintains a zero tolerance approach towards fraud/corruption;
• ensure DTP develops appropriate processes and procedures to manage and mitigate the risk of fraud/corruption;
• ensure all relevant parties are aware of their responsibilities for identifying exposures to fraudulent/corrupt activities and for establishing controls and procedures for preventing such fraudulent/corrupt activity and/or detecting such fraudulent/corrupt activity when it occurs;
• provide guidance to staff/volunteers/contractors as to action which should be taken where they suspect any fraudulent/corrupt activity;
• provide a clear statement to staff/volunteers/contractors of DTP’s zero tolerance approach towards fraud/corruption, including fraud/corruption for the purported benefit of the organisation; and
• provide assurance that any and all suspected fraudulent/corrupt activity will be fully investigated.
  
  

2. Policy

• DTP will not tolerate fraud/corruption in any aspect of its operations.
• DTP will investigate any suspected acts of fraud/corruption, misappropriation or other similar irregularity.
• An objective and impartial investigation, as deemed necessary, will be conducted regardless of the position, title, length of service or relationship with the organisation of any party who might be the subject of such investigation.
• In the case of DTP employees, any fraud/corruption shall constitute grounds for termination of employment. In the case of volunteers, contractors and consultants it shall constitute grounds for termination of the relationship with DTP.
• Any serious case of fraud/corruption, whether suspected or proven, shall be reported to the police.
• Any person reporting a fraud/corruption, or a suspected fraud/corruption, shall suffer no penalty in their employment.
  
  

3. Responsibilities

The Board of DTP has ultimate responsibility for the prevention and detection of fraud/corruption and is responsible for ensuring that appropriate and effective internal control systems are in place.

The Executive Director and each member of the Board and Staff is responsible for investigating instances of fraud/corruption reported to them. All staff must ensure that there are mechanisms in place within their area of control to:

• Assess the risk of fraud/corruption
• Educate employees about fraud/corruption prevention and detection; and
• Facilitate the reporting of suspected fraudulent/corrupt activities.

Management should be familiar with the risk areas of fraud/corruption within their area of responsibility and be alert for any indications of such conduct.

All staff/volunteers/contractors share in the responsibility for the prevention and detection of fraud/corruption in their areas of responsibility. All staff/volunteers/contractors have the responsibility to report suspected fraud/corruption. Any staff member, volunteer or contractor who suspects fraudulent/corrupt activity must immediately notify their supervisor or those responsible for investigations.

In situations where a supervisor is suspected of involvement in the fraudulent/corrupt activity, the matter should be notified to the next highest level of supervision or to the Executive Director, or if it concerns the Executive Director to the Board.

4. Processes

Fraud/corruption prevention accounting procedures shall be incorporated in the organisation’s policies relating to Authority to Sign Cheques, Reimbursement of Expense, Financial Transaction (credit and debit) Cards, Acceptable Use of Computers, Cash Management & Income Handling, and any other relevant policies.

Fraud/corruption prevention procedures shall be incorporated in the organisation’s policies relating to Staff Recruitment and Staff Induction.

All complaints of suspected fraudulent/corrupt behaviour must be reported to the Executive Director:

• Upon notification or discovery of a suspected fraud/corruption, the Executive Director will promptly arrange to investigate the suspected fraud/corruption. The Executive Director will make every effort to keep the investigation confidential; however, members of the Board may be consulted in conjunction with the investigation.
• After an initial review and a determination that the suspected fraud/corruption warrants additional investigation, the Executive Director shall coordinate the investigation with the appropriate law enforcement officials. Internal or external legal representative will be involved in the process, as deemed appropriate.
• Once a suspected fraud/corruption is reported, immediate action will be taken to prevent the theft, alteration, or destruction of relevant records needs to occur. Such actions include, but are not necessarily limited to, removing the records and placing them in a secure location, limiting access to the location where the records currently exist, and preventing the individual suspected of committing the fraud/corruption from having access to the records.
• When a prima facie case of fraud/corruption has been established the matter shall be referred to police. Any action taken by police shall be pursued independent of any employment–related investigation by the organisation.
• If a suspicion of fraud/corruption is substantiated by the investigation, disciplinary action, up to and including dismissal, shall be taken by the appropriate level of management.
  
  

The organisation will also pursue every reasonable effort, including court ordered restitution, to obtain recovery of the losses from the offender.

Vendors and contractors shall be asked to agree in writing to abide by these policies and procedures.

No employee of the organisation, or person acting on behalf of the organisation in attempting to comply with this policy either through reporting an incident or participating in an investigation shall:

• be dismissed or threatened to be dismissed;
• be disciplined or suspended, or threatened to be disciplined or suspended;
• be penalised or any other retribution imposed; or
• be intimidated or coerced.
  
  

Violation of this section of the Policy will result in disciplinary action, up to and including dismissal.

If an allegation is made in good faith, but it is not confirmed by the investigation, no action will be taken against the originator.

5. Approval

The DTP Board of Directors adopted this policy on fraud/corruption:

Date of Adoption: 24th July 2014
Renewed: 8th December 2020 
Date for Renewal: 8th December 2023.