Anti-Fraud & Whistleblowing Policy
GFTH is committed to managing its resources responsibly and maintaining trust with the people it serves, its partners, staff, donors and the wider public. Fraud, bribery, corruption, conflicts of interest and other forms of misconduct can undermine that trust and can directly affect the people and communities GFTH exists to support.
This policy explains GFTH’s approach to preventing, identifying, reporting and responding to suspected fraud, bribery, corruption and other serious wrongdoing. It also sets out the protection GFTH provides to people who raise concerns in good faith.
Our commitment
GFTH does not accept fraud, bribery or deliberate misuse of organisational resources.
Financial resources, programme funds, property, information and other organisational assets must be used only for legitimate and authorised purposes. People working with or on behalf of GFTH are expected to act honestly, responsibly and in the interests of the organisation and the people it serves.
The purpose of this policy is not only to respond when something goes wrong. It is also to establish controls that make misconduct harder to conceal and easier to identify.
What do we mean by fraud?
Fraud generally involves deliberate deception intended to obtain an improper benefit, cause a loss or conceal wrongdoing.
Depending on the circumstances, this may include falsifying records, submitting false expenses, misrepresenting programme expenditure, manipulating procurement processes, misusing organisational funds, creating false documentation or deliberately concealing relevant information.
An honest mistake, administrative error or misunderstanding is not automatically fraud. The circumstances, intent and available evidence will be considered when reviewing a concern.
Bribery and improper payments
GFTH does not permit bribery or the use of improper payments to influence decisions.
No staff member, representative, partner, supplier or other person acting for GFTH should offer, request, authorise or accept an improper payment, benefit or advantage in order to influence a decision, secure an unfair benefit or avoid a legitimate requirement.
Any concern involving a suspected bribe or improper payment should be reported promptly through the whistleblowing or complaints mechanism.
Conflicts of interest
A conflict of interest can arise when a person’s personal, financial, family or other interests could influence, or appear to influence, an organisational decision.
GFTH requires relevant conflicts of interest to be declared and recorded. This includes circumstances involving procurement, recruitment, programme decisions, partner selection, funding decisions or other situations where a personal relationship or private interest could affect impartial judgement.
Declaring a conflict does not automatically mean that a person has acted improperly. Disclosure allows GFTH to determine what safeguards or additional review may be appropriate.
Procurement and financial controls
Procurement and expenditure decisions should follow the controls established by GFTH’s governance and financial procedures.
GFTH’s governance framework requires competitive quotation for procurement above the approved threshold. The exact threshold will be published once the applicable internal procedure has been finalised.
Programme approval, fund disbursement and outcome verification are intended to be handled through separate functions so that no single individual can approve and release a payment without appropriate independent control.
These safeguards are intended to reduce the risk of fraud, financial misuse and conflicts of interest while creating a clear record of organisational decisions.
Examples of conduct that should be reported
Concerns that may require reporting include, but are not limited to:
- suspected theft or misuse of GFTH funds, assets or property;
- false invoices, receipts, claims or financial records;
- deliberate misrepresentation of programme expenditure or beneficiaries;
- suspected bribery or improper payments;
- concealment of a material conflict of interest;
- manipulation of procurement, supplier selection or programme decisions;
- unauthorised use of organisational information or resources; and
- deliberate attempts to conceal serious misconduct or prevent an investigation.
Who can raise a concern?
Anyone who has a genuine concern about suspected fraud, bribery, corruption or serious misconduct connected with GFTH may raise that concern.
This may include staff members, volunteers, programme participants, suppliers, contractors, training providers, institutional partners, community members or other people who interact with GFTH.
A person does not need to be certain that misconduct has occurred before raising a concern. A reasonable and good-faith concern should be reported so that it can be reviewed appropriately.
Whistleblowing in good faith
Whistleblowing means raising a serious concern about suspected wrongdoing through an appropriate reporting channel so that the matter can be reviewed.
GFTH encourages people to raise concerns in good faith rather than remain silent because they are uncertain about what may happen after making a report.
A person who raises a genuine concern should not be treated adversely simply because the concern turns out not to be substantiated, provided that the concern was raised honestly and without deliberately providing false information.
Protection against retaliation
GFTH is committed to non-retaliation for people who raise a complaint or whistleblowing concern in good faith.
Retaliation may include intimidation, threats, harassment, unfair treatment, exclusion or other adverse action taken because a person raised a genuine concern or participated appropriately in a review.
Anyone who believes they have experienced retaliation after raising a concern should report it through the same reporting mechanism or another appropriate GFTH contact.
How to report a concern
Concerns should be reported through the GFTH complaints or designated whistleblowing channel:
Email:
info@gfthbd.org
Dedicated whistleblowing contact:
[To be confirmed]
Telephone:
[To be confirmed]
When making a report, it is helpful to provide as much relevant information as possible, including what happened, when and where it happened, who may be involved and whether supporting documents or other evidence are available.
People should not put themselves at risk in order to obtain evidence. Information should be shared only through lawful and appropriate means.
Anonymous reports
GFTH recognises that some people may be uncomfortable identifying themselves when reporting a concern.
Where the organisation’s reporting arrangements allow anonymous reporting, information should be provided with as much detail as possible so that the concern can still be assessed.
Because anonymous communication can limit GFTH’s ability to ask follow-up questions or provide an update, people are encouraged to identify themselves where they feel safe to do so.
What happens after a report?
Reported concerns should be reviewed proportionately and confidentially. GFTH will assess the information available and determine whether further review, investigation, safeguarding action, financial review or another response is appropriate.
Not every concern will result in a formal investigation. The response will depend on the nature and seriousness of the allegation, the available evidence and any relevant legal, safeguarding or organisational considerations.
Where appropriate, information may be referred to the relevant authority or professional adviser.
Confidentiality
GFTH will seek to handle reports and related information discreetly and limit access to people who have a legitimate reason to know.
Confidentiality cannot be guaranteed in every circumstance. Information may need to be disclosed where required by law, necessary to protect someone from serious harm, or otherwise necessary for a proper investigation or organisational response.
False or malicious reports
GFTH encourages good-faith reporting, but deliberately making a false allegation, knowingly providing false information or using the whistleblowing mechanism to harass another person is not acceptable.
Concerns will therefore be assessed on the information available rather than on assumptions about the person making the report.
Responsibilities of people working with GFTH
Staff, volunteers, contractors, programme partners and other people working with or on behalf of GFTH are expected to understand and follow the organisation’s applicable financial, procurement, safeguarding and governance requirements.
People should raise concerns when they become aware of conduct that may involve fraud, bribery, corruption, serious misconduct or deliberate misuse of organisational resources.
Relationship with other GFTH policies
This policy should be read together with GFTH’s other organisational policies and safeguards, including the Safeguarding & Child Protection Policy, Privacy Policy, Photography & Consent Policy and Complaints & Feedback arrangements.
Where a concern involves safeguarding, personal data, harassment, photography or another specialised issue, the relevant policy may provide additional reporting and response procedures.
Review of this policy
GFTH will review this policy as its governance structures, financial controls, programme operations and organisational requirements develop.
Any material update will be reflected in the version published on this website.
Contact GFTH
For a general concern or to ask how to report a suspected fraud, bribery or whistleblowing matter, contact:
GFTH
info@gfthbd.org