This policy sets out Peter Hewitt Care for Africa Foundation Inc’s policy regarding the prevention and investigation of suspected financial wrongdoing by employees and others with a business relationship with the organisation.
This policy applies to any wrongdoing or suspected wrongdoing, including fraud, corruption, terrorism financing, money laundering and violation of sanctions imposed by the Australian government. This policy applies to staff and volunteers, Board Directors, vendors, contractors, and any other party with a business relationship with CfA Australia or CfA UK, including overseas implementing branches or partners.
‘fraud” is defined as dishonestly obtaining a benefit, or causing a loss, by deception or other unlawful and/or unethical means. It extends beyond the legal definition of fraud to benefits obtained that can be both tangible and intangible. It encompasses activities and/or behaviours broader than misuse and theft of money.
This definition of fraud includes the following:
“Corruption” is defined as the offering, giving, soliciting, or acceptance of an inducement or reward that may improperly influence the action of a person or entity. Some examples of corruption include:
“Money Laundering” is defined as the process of concealing the origin, ownership or destination of illegally or dishonestly obtained money and hiding it within legitimate economic activities to make them appear legal.
Australian Sanction laws implement sanctions of the United Nations Security Council together, including the terrorist list with autonomous sanctions.
“Terrorism Financing” — intentionally providing or collecting funds and being reckless as to whether those funds would be used to facilitate or engage in a terrorist act.
“Board” means the Board of the organisation.
“Management”, means the Chief Executive Officer, General Manager, other Managers, Supervisors and other individuals who manage or supervise funds or other resources, including managing staff.
‘Staff and volunteers’ are people who hold contracts with CfA, whether this be a permanent contract, fixed term contract or volunteer agreement.
The term ‘person’ or ‘persons’ refers to one or many participants, staff and/or volunteers.
CfA Australia is committed to protecting funds and other property entrusted to it by donors from attempts by members of staff, volunteers, the public, contractors, sub-contractors, partners, partner staff, own staff and volunteers, or Board members, to gain financial or other benefit by deceit. We will take all reasonable steps to prevent financial wrongdoing; and will act promptly when actual or suspected financial wrongdoing identified.
The approval of the CEO shall be sought prior to reporting any incidents of fraud or corruption to external authorities.
All employees have a duty to report concerns they have, or information provided to them, about the possible fraudulent or corrupt activity of any employee, Board member, contractor, vendor, or any other party with an association with CfA Australia.
Any employee who has a reasonable basis for believing wrongdoing has occurred must report the suspected act immediately.
Wrongdoing can be reported orally in person or by telephone, or in writing to a supervisor or a more senior manager. Where reports are made orally we will ensure the report is documented and followed up.
If the employee suspects that the supervisor or manager could be involved, or could have a conflict of interest; then the employee should report the matter to a more senior manager or the CEO.
Where the whistleblower wishes to remain anonymous the report can be addressed to
Any person who reports an actual or suspected fraud in good faith, shall be protected as set out in the published Whistle-Blower Policy
If at any time, a staff member believes that the action taken in response to the matter reported is inappropriate or insufficient; the employee must notify the CEO in the first instance and then, the Chair of audit and risk committee or the Board of Trustees in the UK.
This policy takes effect from the date of approval by the Board as noted below.
Amendments to this policy shall be recommended to the Board from time to time as deemed appropriate by the CEO following review by the Audit and Risk Committee. This policy will be reviewed at least every 3 years from the date of the previous approval.
CFA-P9.V3 Financial Wrongdoing Policy
Effective Date: 20 September 2020
Approved By: Board of Management.
Controlled Document — Printed Versions are not controlled. CFA