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 workforce member or Akvo partner is suspected of fraud, corruption, other misuses of funds including non-delivery of agreed deliverables, and undesirable behaviour such as discrimination or sexual harassment. 

2 – Scope

This policy applies to all Akvo workforce members, including but not limited to full-time employees, part-time employees, contractors, trainees, volunteers 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 the development sector 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 workforce 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 workforce member of Akvo will offer, seek or accept remuneration, compensation or benefit of any type that could be interpreted as an illegal or corrupt practice from any other party. Any such practices will be a valid reason for dismissal.

  • Workforce 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 workforce members, they should be fair, in writing, 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.
  • Akvo workforce members are not allowed to negotiate and to sign contracts and agreements between their relatives and Akvo. 
  • Akvo workforce 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 workforce member suspects that a possible conflict of interest may occur, this should be discussed with his/her line manager or Akvo’s confidential counsellor. Akvo will, while striving for fairness and impartiality, do everything in its power to prevent workforce members from (financial) harm.
  • Workforce members are not allowed to maintain a conflict of interest.
Corrective and Sanction policy and procedure
  • When an Akvo workforce member unwillingly or unknowingly becomes involved in corruptive activities, the supervisor will take notice of this and discuss with the workforce member the nature of the activities and the potential damage that the activities may inflict on the workforce member and the organisation. In the specific case of possible corruption related to the Director(s), the Chairman of the Supervisory Board is considered as acting supervisor. The supervisor will support the workforce member to remedy the situation.
  • In case a workforce member is involved in corruption and their intentions are unclear, and/or there is no reason to assume they are involved unwillingly and unknowingly, the workforce member will receive an official warning from the Director(s).
  • In that case, the workforce member is obliged to formulate an action plan within one week, explaining what they will do to remedy the situation and prevent repetition. If the Director(s) agrees with the action, a check will be done upon completion by the direct supervisor. The agreed plan will be filed in the HR dossier of the workforce member. The supervisor will report to the Director(s) on the process of implementation until full completion. If the Director(s) has no confidence that possible repetition is sufficiently prevented, this will lead to the dismissal of the workforce member concerned.
  • A second time of involvement in a proven corruptive activity will lead to the immediate dismissal of the workforce member concerned.
  • When one of the Director(s) is involved in corruption and their intentions are unclear, the Supervisory Board will be involved to take appropriate measures.

3.2 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.
  • In order to check the trustworthiness of partners, Akvo uses the following criteria:
    A partner is an organisation with professional staff, working in multiple regions or countries on development aid projects. 
  • A partner has a substantial track record of successful (development aid) projects.
  • A 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 and 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 partner.
Correction and sanction policy
  • When there is a suspicion that the partner is involved in fraud, corruption or undesirable behaviour such as discrimination or sexual harassment, the Akvo Director(s) will immediately discuss the issue with the partner. When fraud or undesirable behaviours such as discrimination or sexual harassment 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), Akvo will start an investigation.
  • When an investigation shows that fraud has been committed, the relationship between the partner and Akvo will be immediately terminated and all running projects with the partner will be cancelled. When this happens, the findings of the investigation will be communicated on the Akvo website and the Director(s) of Akvo will immediately inform the Supervisory Board.
  • When an investigation shows that undesirable behaviour such as discrimination or sexual harassment has been committed and if no appropriate measures have been taken by the partner, the relationship between the partner and Akvo will be immediately terminated and all running projects with the partner will be cancelled. When this happens, the Director(s) of Akvo will immediately inform the Supervisory Board.
  • If the 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 Complaints Policy.