Anti-corruption and sanction policy

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1 – Purpose

The purpose of this policy is to describe preventive measures and a sanction policy in case an Akvo staff member, an Akvo Support partner or an Akvo Field partner is suspected of fraud, corruption, or other misuse of funds, including non-delivery of agreed deliverables. The aim is to prevent the abuse of money for personal or other aims over and above those agreed upon in the contracts with her partners.

2 – Scope

This policy applies to all Akvo workforce members, including, but not limited to full-time employees, part-time employees, trainees, volunteers, contractors, and temporary workers. All workforce members and Partners are made aware of the existence of this anti-corruption and sanction policy.

3 – Policy

3.1 Akvo workforce members

Abuse of Power (identical to paragraph in Akvo Code of Conduct)

Working in International Development is a delicate business; Akvo wishes to be respected by its partners and intends to guarantee this by applying strong criteria.

  • It is prohibited for staff members to abuse the power that is inherent to their position for their own advantage or for the advantage of their friends or relatives.
  • No staff member of Akvo will offer, nor seek, accept or get promised from other parties, for him or herself, or from any other party a remuneration, compensation or benefit of whatever type, that could be interpreted as an illegal or corrupt practice. Would any of these practices occur, it will be a reason for dismissal.
  • Staff members are not allowed to accept any personal gifts from beneficiaries or partner organisations and their employees, in the form of money, goods or services that exceed the value of 50 Euros.
  • Where contracts for services are realised with the input of staff members, they should be fair, in writing and in the standard Akvo format, and signed by all parties involved.
Conflicts of interest (identical to paragraph in Akvo Code of Conduct)

Cases may occur where personal and professional (Akvo) interests are in conflict with each other, especially in the area of service delivery and professional contracts:

  • Staff members working for Akvo are not allowed to negotiate and to sign contracts and agreements between their relatives and Akvo.
  • Staff members with their own business or financial interests in certain companies are not allowed to sign contracts between Akvo and these companies under any circumstances.
  • As soon as a staff member suspects that a possible conflict of interest may occur, this should be discussed with the supervisor. Akvo will, while striving for fairness and impartiality, do everything in its power to prevent staff members from becoming (financially) harmed.
  • Staff members are not allowed to maintain a conflict of interest.
Corrective and Sanction policy (see procedures for details)
  • When an Akvo staff member would unwillingly or unknowingly get involved in corruptive activities, the supervisor will Support the staff member to remedy the situation.
  • In case a staff member gets involved in corruption and his/her intentions are unclear, and/or there is no reason to assume he/she was getting involved unwillingly and unknowingly, the staff member will get an official warning from the Director(s).
  • The staff member is obliged to formulate an action plan within one week, explaining what he/ she will do to remedy the situation and prevent repetition. In case the Director(s) agrees with the action, a check upon the realisation will be done by the direct supervisor. The agreed plan is filed in the H&R dossier of the staff member. The supervisor reports to the Director(s) on the process of implementation until full completion. In case the Director(s) has no confidence that possible repetition is sufficiently prevented, this leads to the dismissal of the staff member concerned.
  • A second time of involvement in a proven corruptive activity will lead to immediate dismissal of the staff member concerned.

3.2 Field partners

Akvo Field partners implement the water and sanitation projects listed in Akvo, in collaboration with the local community. The relationship which Akvo has with the Field partner runs via the Support partner, who has a well-established working relationship with the Field partner. If there is an issue with a Field Partner, the Support partner is the first point of contact for Akvo. The procedures which the Support partner has in dealing with non-delivery, fraud and corruption will therefore be leading in dealing with issues with Field Partners.

Preventive measures

In most cases, Akvo does not have a direct relationship with the Field partner. Therefore, the most important prevention against untrustworthy Field partners is the choice of solid Support Partners (see below).
In order to further guarantee the trustworthiness of Field Partners, Akvo uses the following criteria for Field partners:

  • A Field partner has a Support partner which approves and supports the implementation of its projects, and monitors and evaluates projects.
  • A Field partner is registered as a foundation, NGO, or other type of organisation.
  • A Field partner has a sustained relationship with the communities in the region in which their project is implemented.
  • A Field partner has an office in the region in which the project is implemented.
  • A Field partner has a proven track record in development projects.
Correction and sanction policy
  • If a Field partner cannot realise the activities or deliver the reports as agreed in the Akvo project description and in the agreement with the Support partner, the Support partner will initiate a process to remedy this situation, according to its own procedures. If this process leads to a change in scope, schedule or budget, this will be communicated to Akvo.
  • If the proposed change in scope or planning is significant (a change of over 20%) or if the proposed change is to increase the budget, the change should be discussed with Akvo. Significant changes to the scope and schedule of a project and any increase to the cost of a project can only be incorporated in the project description with the agreement of Akvo.
  • The Support partner will supply a written explanation of any significant changes in scope, and schedule (changes of over 20%), which will be published on the project webpage on the Akvo website.
  • If a change in scope results in a lower budget, the difference in funds will be reimbursed to Akvo by the Support partner. Akvo will then redistribute the funds in accordance with its funding policy.
  • If, after the first change of scope, schedule or budget there are no improvements in realising the agreed activities or improving the administration within the period agreed between the Support partner and the Field partner for doing so, Akvo will make a request to the Support partner to claim back payments made to the Field Partner, in accordance with the procedures of the Support partner for doing so, and reimburse to Akvo that part of the payments that originated from funds collected by Akvo.
  • When there is a suspicion that the Field Partner is involved in fraud or corruption the Akvo Director(s) immediately discusses the issue with the Support Partner of the Field partner. When fraud is suspected (fraud can involve one or all of the following: misrepresentation of facts, breach of contractual responsibilities, suppression of the truth, and omission of critical facts), the appropriate policy of the Support partner for dealing with suspicion of fraud is followed.
  • If the Support partner decides not to initiate an external audit after a suspicion of fraud has arisen, Akvo may initiate an external audit.
  • As long as there is an ongoing fraud investigation, no payments are made. If the investigation shows that no fraud has been committed, payments can continue.
  • When a fraud investigation shows that fraud has been committed the relationship between the Field partner and Akvo is immediately terminated and all running projects with this Field partner are cancelled. When this happens the findings of the investigation are communicated on the Akvo website. The procedures of the Support partner for claiming back previous payments are followed. The Director(s) of Akvo immediately inform the Board.
  • If a Field Partner has been shown to commit fraud, the Support partner should demonstrate towards Akvo that the Support Partner had no knowledge of the fraud, and that it took all reasonable measures to prevent fraud. If the explanation provided by the Support partner is deemed unsatisfactory by the Akvo Director(s), Akvo will terminate the relationship between Akvo and the Support partner.
  • If the Support partner does not agree with the decision of Akvo, it can file a complaint or an appeal, which will be processed according to the Akvo Complaint Policy.

3.3 Support partners

Preventive measures

The most important preventive measure is to ensure that a thorough investigation of the capacity of potential partners is carried out before deciding to enter into agreements with them. Akvo Support partners are organisations which support the Field partners in different ways. Among others, they are responsible for the approval of project plans, and for monitoring and evaluation of projects of Field Partners.
Akvo checks potential new Support partners against the list of criteria for Support partners (see below), making additional inquiries through our partner network. The Support partners bring new Field Partners into the Akvo system.
In order to check the trustworthiness of Support Partners, Akvo uses the following criteria for Support partners:

  • A Support partner is an organisation with professional staff, working in multiple regions or countries on water and sanitation projects.
  • A Support partner has a substantial track record of successful water and sanitation projects.
  • A Support partner is embedded in international water and sanitation networks and has multiple links with other professional organisations.
  • A Support partner is accredited by a national accrediting body which inspects public interest bodies (if this is available in the country), and ensures they meet high standards of management and integrity, awards public certificates confirming that the organisation is well-run and deserving of support.
  • Funds received from Akvo are part of the financial administration and financial reporting of the Support partner.
Correction and sanction policy
  • If a Support partner does not pay the membership fees due within one month of the date of the invoice, a reminder is send to the Support partner. If the Support partner does not respond with payment after a further period of one month, a final reminder is send to the Support partner. If the Support partner does not respond to the final invoice within one month, Akvo will terminate the relationship with the Support partner.
  • If, at the end of a project the delivered actions and hardware are found to differ substantially from what was agreed in the project plan, the Support partner will be asked to provide an explanation of the difference. If the explanation is deemed unsatisfactory by the Akvo responsible officer, he/she will discuss this with the Support partner. If this does not lead to a satisfactory solution, the Support partner will be issued a letter of warning.
  • If for a second time the delivered actions and hardware differ substantially from what was agreed in the project plan without a satisfactory explanation, Akvo will terminate the relationship with the Support partner.
  • If a problem with a Field partner results in Akvo claiming back the payments from the Field Partner, the Support partner will take reasonable actions in support of claiming back payments and reimbursing them to Akvo.
  • When there is a suspicion that a Support partner is involved in fraud or corruption the Akvo Director(s) immediately discusses the issue with the Support Partner. When fraud is suspected (fraud can involve one or all of the following: misrepresentation of facts, breach of contractual responsibilities, suppression of the truth, and omission of critical facts), payments are stopped immediately, and an external audit is initiated by Akvo.
  • As long as there is an ongoing fraud investigation no payments are made. If the investigation shows that no fraud has been committed, payments can continue.
  • When a fraud investigation shows that fraud has been committed the relationship between the Support partner and Akvo is immediately terminated. When this happens the findings of the investigation are communicated on the Akvo website. All previous payments are claimed back. The Director(s) of Akvo immediately inform the Board.

4 – Procedures

4.1 Akvo workforce members

  • When an Akvo staff member would unwillingly or unconsciously get involved in corruptive activities, the supervisor of the staff member will take notice of this and discuss with the staff member the nature of the activities and the potential damage that the activities may inflict on the staff member and the organization. (in the specific case of possible corruption related to the Director(s) the chairman of the Board is considered as acting “supervisor” and will act accordingly). The supervisor will support the staff member to remedy the situation.
  • In case a staff member got involved in corruption and his/her intentions are unclear, and/or there is no reason to assume he/she was getting involved unwillingly and unknowingly, the staff member will get an official warning from the Director(s).
  • In that case, the staff member is obliged to formulate an action plan within one week, explaining what he/she will do to remedy the situation and prevent repetition.
  • In case the Director(s) agrees with the action, a check upon the realisation will be done by the direct supervisor. The agreed plan is filed in the H&R dossier of the staff member. The supervisor reports to the Director(s) on the process of implementation until full completion.
  • In case the Director(s) has no confidence that possible repetition is sufficiently prevented, this leads to the dismissal of the staff member concerned.
  • A second time of involvement in a proven corruptive activity will lead to immediate dismissal of the staff member concerned.

4.2 Field partners

In case of non-delivery
  • If a Field partner cannot realise the activities or deliver the reports as agreed in the Akvo project description and in the agreement with the Support partner, the Support partner will initiate a process to remedy this situation, according to its own procedures. If this process leads to a change in scope, schedule or budget, this will be communicated to Akvo.
  • If the proposed change in scope or planning is significant (a change of over 20%) or if the proposed change is to increase the budget, the change should be discussed with Akvo. Significant changes to the scope and schedule of a project and any increase to the cost of a project can only be incorporated in the project description with the agreement of Akvo.
  • The Support partner will supply a written explanation of any significant changes in scope, and schedule (changes of over 20%), which will be published on the project webpage on the Akvo website.
  • If a change in scope results in a lower budget, the difference in funds will be reimbursed to Akvo by the Support partner. Akvo will then redistribute the funds in accordance with its funding policy.
  • If, after the first change of scope, schedule or budget there are no improvements in realising the agreed activities or improving the administration within the period agreed between the Support partner and the Field partner for doing so, Akvo will make a request to the Support partner to claim back payments made to the Field Partner, in accordance with the procedures of the Support partner for doing so, and reimburse to Akvo that part of the payments that originated from funds collected by Akvo.
In case of suspicion of fraud
  • When there is a suspicion that the Field Partner is involved in fraud or corruption the Akvo Director(s) immediately discusses the issue with the Support Partner of the Field partner. When fraud is suspected (fraud can involve one or all of the following: misrepresentation of facts, breach of contractual responsibilities, suppression of the truth, and omission of critical facts), the appropriate policy of the Support partner for dealing with suspicion of fraud is followed.
  • If the Support partner decides not to initiate an external audit after a suspicion of fraud has arisen, Akvo may initiate an external audit.
  • As long as there is an ongoing fraud investigation, no payments are made. If the investigation shows that no fraud has been committed, payments can continue.
In case of actual fraud
  • When a fraud investigation shows that fraud has been committed the relationship between the Field partner and Akvo is immediately terminated and all running projects with this Field partner are cancelled. When this happens the findings of the investigation are communicated on the Akvo website.
  • The procedures of the Support partner for claiming back previous payments are followed.
  • The Director(s) of Akvo immediately inform the Board.
  • If a Field Partner has been shown to commit fraud, the Support partner should demonstrate towards Akvo that the Support Partner had no knowledge of the fraud, and that it took all reasonable measures to prevent fraud. If the explanation provided by the Support partner is deemed unsatisfactory by the Akvo Director(s), Akvo will terminate the relationship between Akvo and the Support partner.
  • If the Support partner does not agree with the decision of Akvo, it can file a complaint or an appeal, which will be processed according to the Akvo Complaint Policy.

4.3 Support partners

In case of non-payment of fees
  • If a Support partner does not pay the membership fees due within one month of the date of the invoice, a reminder is send to the Support partner.
  • If the Support partner does not respond with payment after a further period of one month, a final reminder is send to the Support partner.
  • If the Support partner does not respond to the final invoice within one month, Akvo will terminate the relationship with the Support partner.
In case of non-delivery
  • If, at the end of a project the delivered actions and hardware differ substantially from what was agreed in the project plan, the Support partner will be asked to provide an explanation of the difference.
  • If the explanation is deemed unsatisfactory by the Akvo responsible officer, he/she will discuss this with the Support partner.
  • If this does not lead to a satisfactory solution, the Support partner will be issued a letter of warning.
  • If for a second time the delivered actions and hardware differ substantially from what was agreed in the project plan without a satisfactory explanation, Akvo will terminate the relationship with the Support partner.
  • If a problem with a Field partner results in Akvo claiming back the payments from the Field Partner, the Support partner will take reasonable actions in support of claiming back payments and reimbursing them to Akvo.
In case of suspicion of fraud
  • When there is a suspicion that a Support partner is involved in fraud or corruption the Akvo Director(s) immediately discusses the issue with the Support Partner.
  • When fraud is suspected (fraud can involve one or all of the following: misrepresentation of facts, breach of contractual responsibilities, suppression of the truth, and omission of critical facts), payments are stopped immediately, and an external audit is started.
  • As long as there is an ongoing fraud investigation no payments are made.
  • If the investigation shows that no fraud has been committed, payments can continue.
In case of actual fraud
  • When a fraud investigation shows that fraud has been committed the relationship between the Support partner and Akvo is immediately terminated.
  • The findings of the investigation are communicated on the Akvo website.
  • All previous payments are claimed back.
  • The Director(s) of Akvo immediately inform the Board.