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This Code of Conduct adopts the widely used definition of corruption as:

“The misuse of entrusted power for private gain”

Recognizing that there is no universal or comprehensive definition of corrupt behaviour, this Code of Conduct establishes that corrupt and fraudulent practices comprise the following acts:


Fraud and fraudulent behaviour is understood as a deliberate and planned action by management teams or others for personal profit. Fraud includes false representation, extortion, conspiracy, collusion, deception, blackmailing, nepotism, theft and embezzlement of funds, forgery, counterfeiting of documents, and falsification or misrepresentation of costs related to project activities, travel expenses, per diem, etc. A zero tolerance towards all types of fraud is paramount.


Corrupt behaviour and practice is understood as offering facilitation payment (also called “grease payment”, “processing fees” or bribery) in order to obtain or expedite services in excess of normal specified charges. A zero tolerance towards all types of corrupt behaviour is paramount.

Misuse of funds and assets:

Misuse of funds and assets is understood as the utilization of funds and assets (such as cars, phones, etc.) for other purposes than the one stated in the application for funding of projects and activities; and negligent or improper maintenance of assets. A zero tolerance towards all types of misuse of funds and assets is paramount.

Serious irregularities:

Serious irregularities are understood as the lack of proper accounting, delayed or missing financial reports to partners and donors, lack of cost effective and efficient management of assets and financial and human resources, and other forms of mismanagement.

Acceptance or offering of gifts or favours :

Acceptance or offering of any gifts or favours that are more than “token gifts” i.e. pens, desk diaries, etc. An employee shall not solicit or receive, directly or indirectly, any gift, favor or benefit in exchange for official action or inaction, or that may influence or appear to influence the exercise of his or her functions, duties or judgment. This also includes benefits awarded to ‘third parties’ such as partner/spouse, children, etc.

Failure to disclose or enable full transparency:

Failure to disclose or enable full transparency of contract management or any potential conflict of interest with partner organisations, service providers, suppliers and business partners. This includes any attempt to conceal close family relations, shareholder arrangement or other decisive relationships.