Financial Wrongdoing Policy

1. Purpose

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.

2. Scene

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.

3. Definitions

3.1 Fraud

‘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:

  • Forgery or alteration of documents (cheques, bank drafts, bank statements, time sheets, invoices, quotations, agreements, etc.) or bank accounts belonging to CfA Australia.
  • Misrepresentation of information on documents.
  • Misappropriation of funds, supplies, or assets.
  • Theft, disappearance, or destruction of assets.
  • Improprieties in the handling or reporting of money or financial transactions. pastedGraphic_5.png Authorising or receiving payments for goods not received or services not performed.
  • Authorising or receiving payment for hours not worked.
  • Inappropriate use of the organisation’s records and disclosing confidential and proprietary information to outside parties, without consent.

3.2. Corruption

“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:

  • Bribery
  • Conspiracy
  • Extortion

3.3. Money Laundering

“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.

3.4. Violation of Sanctions imposed by Australian government

Australian Sanction laws implement sanctions of the United Nations Security Council together, including the terrorist list with autonomous sanctions.

3.5. Terrorism Financing

“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.

3.6. Board

“Board” means the Board of the organisation.

3.7. Management

“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.

3.8. Staff and Volunteers

‘Staff and volunteers’ are people who hold contracts with CfA, whether this be a permanent contract, fixed term contract or volunteer agreement.

3.9. Person

The term ‘person’ or ‘persons’ refers to one or many participants, staff and/or volunteers.

4. Policy and Policy Principles

4.1. Policy

 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.

Policy principles 

CfA Australia:

  • maintains a ‘zero tolerance’ attitude towards financial wrongdoing. Financial wrongdoing, regardless of who this is committed against, will constitute misconduct and may be grounds for dismissal. It may lead to actions to recover any losses sustained by CfA Australia as a result of such wrongdoing (including referral to law enforcement authorities)
  • requires that all staff must report any case of suspected or detected wrongdoing immediately it is detected or suspected. Reports must be made in good faith and be as thorough as possible. False or malicious allegations may result in disciplinary actions
  •  adopts a risk management approach to the prevention, detection and investigation of suspected fraudulent and corrupt activity that is incorporated into its business processes, management practices, internal controls and related activities;
  • commits to creating an organisational culture that prevents wrongdoing, including senior management example, stringent recruitment processes, monitoring and evaluation to ensure funds are spent as expected, inhouse training and appropriate reporting mechanisms.
  • will prosecute or apply other appropriate sanctions against those who have committed fraud and engaged in corrupt conduct.

5. Policy in Action

  • Fostering and maintaining the highest standards of ethical behaviour; 
  • Stringent recruitment procedures
  • Regular assessment of financial wrongdoing risk at program, fundraising and office level considers how wrongdoing could be perpetrated in our operating environment. Fraud, corruption, money laundering, terrorism financing and violation of sanctions imposed by Australian government covered by risk assessment.
  • Documentation and operation of controls to mitigate the identified risks and regular checks that these are implemented effectively.
  • Publicising this policy and training staff on the risks and application of the controls pastedGraphic_4.png Ensuring that employees directly involved in prevention of financial wrongdoing receive adequate training;
  • Donations only accepted from ethical sources, refunds require authorisation and explicit intent to refuse funds from illegal activities or sources
  • Ensuring investigation of instances of financial wrongdoing and making every effort to recover the proceeds of these acts.
  • Referring incidents (with CEO approval) of wrongdoing to appropriate authorities;
  • Reporting on control activities to the CEO, Audit Committee and the Board. pastedGraphic_9.png Reporting Incidence of Fraud to Board
  • Reporting Prior to signing any agreements for employment, volunteer or Board appointment. New suppliers or partners, the name of the individual or organisation will be checked against the DFAT ‘Consolidated List’ of persons and entities subject to targeted financial sanctions imposed by resolution of the UN Security Council, and the Attorney-General’s Department ‘List of Terrorist Organisations’ as per Division 102 of the Criminal Code 1995.  CfA will not engage with any individuals or entities that appear on those lists.

The approval of the CEO shall be sought prior to reporting any incidents of fraud or corruption to external authorities.

6. Responsibility

  • The governing body of CfA Australia, including the Finance Audit and Risk Committee, has ultimate responsibility for the prevention and detection of financial wrongdoing and for ensuring that appropriate internal control systems are in place.
  • All personnel are responsible for: ensuring that they are familiar with and comply with financial wrongdoing policies and procedures; conducting themselves with integrity and avoiding financial wrongdoing of any kind; demonstrating awareness of prevention of financial wrongdoing practices; and reporting all suspected cases of financial wrongdoing as soon as possible in line with the policy.
  • The Chief Financial Officer is responsible for the design of the internal control environment to ensure that financial wrongdoing is prevented.
  • The Chief Executive Officer is responsible for ensuring that the internal control environment is effective.
  • All staff are responsible for operating in accordance with the internal control environment.
  • The Board (via the Finance & Audit Committee) are responsible for oversight of the internal control environment.
  • Managers have a responsibility to: be aware of areas in their sections that have high risk of financial wrongdoing; role model a zero tolerance for financial wrongdoing culture within their teams and throughout the organisation; ensure that prevention of financial wrongdoing policies and procedures are communicated and understood amongst their teams; and understand the applicable legal environment for their areas.
  • The CEO is responsible for managing the investigation process, including appointment of the investigation team, consideration of reporting the financial wrongdoing to external bodies (in consultation with the governing body), and deciding on disciplinary action. If the CEO is implicated in the financial wrongdoing, this responsibility reverts to the Chair of the governing body,
  • All managers should ensure that they assess the risk of financial wrongdoing in their areas of responsibility, are alert to any indicators of such conduct, ensure that their teams are trained in financial wrongdoing awareness and facilitate reporting of any suspected financial wrongdoing.
  • All staff and volunteers have responsibility for preventing and detecting financial wrongdoing.
  • All Management Committee members are responsible for ensuring they conduct themselves ethically and that they are aware of potential risks of financial wrongdoing at CfA
  • Every employee of CfA has an obligation to assist in upholding this policy. The Board has responsibility for the monitoring and review of this policy.

7. Reporting of Financial Wrongdoing

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.

8. Related Policies

  • Conflict of Interest Policy 
  • Whistle-blower Policy
  • Counter Terrorism Policy

9. Reference Documents

  • Commonwealth Fraud Control Framework
  • Commonwealth Fraud Control Guidelines March 2011
  • Commonwealth Criminal Code Act 1995 (Part 7.3)
  • DFAT ANCP Head Agreement
  • Australian Government Investigations Standards (AGIS)

10. Policy Management

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