Anti corruption & Anti bribery
Version 1.0 | This Policy was approved on 01 March 2022.
Introduction
Definitions
This document employs terms related to the DCDR Advocacy that can be found in the TIOF terminology.
For a structure of The IO Foundation, please visit
The IO Foundation's Organizational Chart
The IO Foundation's Organizational Taxonomy
About this document
This document, hereinafter the Policy, sets out the position maintained by TIOF in matters of Anti-corruption and Anti-bribery that you will need to be aware of while being a TIOF Member. You should familiarize yourself with it and comply with it at all times. Any questions you may have with regard to its contents or what you have to do to comply with it should be referred to your corresponding Team Human Resources Manager.
Any Member who breaches this Policy will face disciplinary action, which could result in dismissal for gross misconduct. Any non-employee who breaches this Policy may have their contract (or equivalent official relationship with TIOF) terminated with immediate effect.
Scope
This document directly applies to:
All TIOF Members
This document indirectly applies to:
The policies set out in this document apply to all TIOF Members unless otherwise indicated. They therefore apply to Members of the Boards (Directors, Advisers, Consultants), Employees, Volunteers and Interns; this is irrespective of their engagement type. They equally apply to all Contributors and will be used as part of the selection criteria when engaging with them.
This Policy applies within all TIOF Spaces, including (although not limited to) management activities, contributions or events; it and also applies when an individual is officially representing the organization in public spaces. Examples of representing the organization include (although not limited to) using an official e-mail address, posting via any official channel or acting as an appointed representative at an event.
Review and Amendments This policy shall be reviewed regularly to ensure its continued relevance and effectiveness. Amendments may be made to adapt to new legal requirements, changing circumstances or to better serve the organization's Mission.
Policy details
Anti corruption and Anti bribery statement
The IO Foundation is committed to conducting its advocacy and all of its initiatives in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, transparently, fairly, with integrity and under the observance of the law in our advocacy, operations, financial management and relationships.
What is bribery?
"Bribe" means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of (although not limited to) money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.
"Bribery" includes offering, promising, giving, accepting or seeking a bribe.
All forms of bribery are strictly prohibited.
If you are unsure about whether a particular act constitutes bribery, raise it with your corresponding Team Human Resources Coordinator.
Specifically, you must not:
give or offer any payment, gift, hospitality or other benefit in the expectation that a transaction advantage will be received in return or to reward any support received;
accept any offer from a third party that you know or suspect is made with the expectation that we will provide a transaction advantage for them or anyone else;
give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure.
You must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.
Gifts and hospitality
This Policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation or marketing our advocacy, initiatives and services.
A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process). All such tokens of appreciation are to be notified to your corresponding Team Human Resources Coordinator.
Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers) and in any case be given in secret.
Gifts must be given in the organization's name, not your name.
Promotional gifts of low value such as branded stationery may be given to or accepted from existing contributors, suppliers and partners.
Record-keeping
You must declare and keep a written record of all hospitality or gifts given or received. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our Financial procedures and record the reason for expenditure.
All accounts, invoices and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness.
Accounts must not be kept "off-book" to facilitate or conceal improper payments.
How to raise a concern
If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must report it in accordance with our Whistleblowing Policy as soon as possible.
Conduct outside of Work
We do not seek to interfere with the personal lives or conduct of our Members. However, some times certain conducts outside of work can interfere with our legitimate advocacy and/or initiatives' interests.
You are expected to conduct your personal affairs in a manner that doesn't adversely affect the integrity, reputation or credibility of yourself and/or The IO Foundation.
Illegal or immoral conduct outside of work by any Member that adversely affects our legitimate advocacy and/or business interests, or other TIOF Member's ability to perform their responsibilities, will not be tolerated.
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