The purpose of this policy is to ensure that NNLE “CDD – Center of Development and Democracy” has appropriate systems and procedures in place to prevent bribery and corruption. We believe, society free from corruption is a basic prerequisite for fair and democratic development and for a sustainable reduction in poverty. Corruption in developmental efforts reduces confidence in, and the desire to finance, these types of projects. Corruption goes against basic values such as justice, democracy, equality, dignity, integrity, transparency and the possibility to demand accountability. This policy is designed to ensure that each part of CDD applies appropriate steps to comply with organizations ethical standards and the law. This policy should form part of the induction of new colleagues and partners.
Definition of Corruption
CDD follows Transparency International’s definition of corruption: ” The abuse of entrusted power for illegitimate individual or group benefit”. Accordingly, corruption is an abuse of trust or position.
The concept of corruption includes occurrences such as the giving or receiving of bribes, blackmail, favoritism, nepotism, swindle, challenge and embezzlement. Other abuses of power such as negligence and mismanagement can also be considered a form of corruption.
Anti-corruption Commitment
CDD’s basic principle is to never accept corruption, and to always take action and report cases of suspected corruption.
CDD will ensure:
• That employees have sufficient knowledge concerning the anti-corruption policy and that it is applied to all undertakings;
• That documented routines, supervision, forms, and contracts that contribute to counteracting corruption are known and used within the organization;
• That there are clear routines and systems for handling suspected cases of corruption;
• That all partner organizations are aware of CDD’s anti-corruption policy.
A deciding factor in the prevention of corruption is the strengthening of organizational culture as it pertains to good governance.
This can take place through:
• Work for democratic processes characterized by broad participation and transparency;
• Evaluation of corruption risks when creating routines, delegation of authority agreements, as well as operational plans, program plans and project plans, including budgets;
• Ensuring that planned projects have clearly formulated goals, expected results and activities as well as routines for follow-up;
• Learning from experiences and continually improving working methods and routines;
• Ensuring that reports from staff members are submitted in accordance with deadlines and that the reports are analyzed and followed-up on;
• Ensuring that gifts to and from partner organizations and suppliers only have a symbolic value;
• Ensuring that when receiving gifts it should be made clear that they are accepted on behalf of CDD;
• Ensuring that in the case of entertainment, a restaurant of normal standard is chosen and that alcohol is consumed in accordance with accepted cultural norms.
Responsibilities
The board members are responsible for the effective design, implementation and operation of the anticorruption policy. The board shall ensure that management is aware of and accepts the policy, and that it is embedded in the corporate culture.
Anticorruption policy shall be published on the organizations official website: www.CDD.ge.
The Chairperson shall be responsible for ensuring that systems are in place to prevent corruption.
The top management shall carry out an annual internal review of the anti-corruption policy, regularly monitor its effectiveness and shall make appropriate recommendations to the board concerning revisions to the policy and other necessary action as appropriate in the light of this review.
Procedures
Employment procedures
CDD’s employment practices shall ensure that:
• Employees, particularly those in management positions or other posts where bribery and corruption may be an issue, shall be vetted before they are employed to ascertain as far as is reasonable that they are the type of person who is likely to comply with the Organization’s anti-corruption policies.
• Employment contracts shall be modified to include contractual obligations and penalties in relation to corruption with specific reference to bribery.
• New employees shall be informed of the organizations principles to ensure that they understand it and the importance of complying with specific reference to anti-corruption.
• Employees shall be required to declare any conflict of interest. Managers should monitor a potential conflicts of interest that may increase the risk of bribery and corruption.
• Disciplinary procedures shall be amended entitling the organization to take appropriate disciplinary action against an employee who commits a corrupt act. These procedures should be specified in the employment contract.
• Caution shall be taken in the provision of performance bonuses and performance targets to ensure that there are adequate safeguards to prevent bonuses and targets resulting in corrupt activity.
Detection procedures:
CDD shall ensure that risk management and financial control Procedures or other processes which check projects, contracts and systems on an appropriate sample basis, each check for any indication of corruption. Checks should cover financial, operational and technical aspects.
Reporting procedures:
CDD has in place internal procedures for reporting corruption in its “Speak Up” confidential reporting system which enables employees to report corruption in a safe and confidential manner to a responsible senior officer of the organization. Employs are obliged to report corruption as soon as they become aware of it to the senior management of the organization.
Keeping records:
CDD shall keep records of organizations matters. These records include matters such as the steps taken to implement the anti-corruption policy, training provided, gifts and hospitality given and received, due diligence carried out, the reasons behind a decision to carry out work in a high risk country, whistle-blowing reports, investigations etc.
The final responsibility for investigating corruption lies with the Chairperson. The Chairperson can delegate the responsibility of investigation to the relevant operational managers. The members of the board and personnel responsible for finances may also be included in the investigation work.
The Chairperson ensures that board is informed about the issue in more serious cases. If the funds in question come from an external source the financier shall be notified immediately.
In the case of suspected corruption CDD shall, if deemed necessary, ensure that an external audit takes place. In the case of a suspected crime the issue will be reported to the police.
If proof of mismanagement or corruption within a partner organization is revealed, CDD shall consider terminating its support to the organization in accordance with the contract. If corrections are not made the contract shall be terminated and CDD will demand that allocated funds are returned.
