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Anti Corruption Policy & Procedures


Omission Misrepresentation Misleads Obtain financial or other benefits Misappropriation of funds Use of funds for purposes other than designated Unauthorised/unbudgeted expenses Expenses for private purposes Nepotism Patronage Financial misconduct


• • • • • •

Abuse of resources which belong to Strømme Foundation Bribery Kickbacks Facilitation payments Personal injury or damage to property Collusion in improper procurement or contracting activities Any attempts to suppress corruption



Acts of bribe, fraud, and corruption are criminal acts and punishable by law. This includes influence peddling if one demands, receives or accepts offer of an advantage that affect management of one’s position or mission.


Ensure that financial and other resources are used solely for the intended purposes. Promote a culture of honesty and openness among the staff and management of Strømme Foundation. Ensure that our procedures and policy are in line with UK Bribery Act, instructions from Norwegian government, other donor government policies and other applicable stakeholders.


Ensure that vulnerable individual or groups are not disadvantaged or exploited by staff members or their associates who commit fraudulent and corrupt acts. Assure members of staff and target populations can safely and confidently raise and report all serious concerns about unethical conduct, suspected fraud and corruption.

POLICY STATEMENT Unless otherwise expressly permitted by or approved in writing under this Policy and Procedures, no Strømme Foundation board member, employee, any of its subsidiaries, or any third party acting on behalf of Strømme Foundation shall make, provide, offer or authorize any payment, gift of any kind or anything of value that can be constituted as a bribe, directly or indirectly, to any official or employee of any national, state, provincial or local government or any government owned or controlled agency or entity.


How can I be transparent? TO ENSURE COMPLIANCE WITH THE ANTI-CORRUPTION POLICY, THE FOLLOWING RULES HAVE BEEN ESTABLISHED TO PROVIDE GUIDANCE FOR BOARD MEMBERS, EMPLOYEES, PARTNERS, SUBSIDIARIES, OR ANY ENTITY ACTING ON BEHALF OF STRØMME FOUNDATION AND ITS SUBSIDIARIES: NO PAYMENT, GIFT, OR ANYTHING OF VALUE MAY BE PROMISED, offered and/or made to any governmental or non-governmental entity, either directly or indirectly such as through a third party, except as expressly permitted in this policy. A GIFT MAY BE PROVIDED, only if it is a promotional gift of modest value and usually bearing the Strømme Foundation logo. Low value gift may be accepted if it is considered culturally offensive if rejected. A written record should be made of all gifts received and where they are of significant value they may be treated as the property of Strømme Foundation and not the individuals.


ALL TRANSACTIONS MUST BE ACCURATELY AND PROPERLY recorded in the books and well documented. Any indication of – or suggestion by – the implementing partners, subsidiaries, or by other employees to make an improper payment, mischaracterize a transaction in Strømme Foundation’s books and records, or redirect payments to a third party should be promptly reported to the appropriate director or through the internet channel.

NO FACILITATING PAYMENT MAY BE MADE by any employee unless it is in response to a medical or safety emergency, i.e. an employee is in imminent jeopardy of serious harm and no other reasonable alternatives are available. Whenever such a payment is made to ensure the safety of an employee, the circumstances of the payment must be immediately documented in writing and submitted to the relevant director. Further, the purpose and the nature of such payments must be accurately recorded in the books and appropriate record maintained.

FALSE, MISLEADING, INCOMPLETE, INACCURATE OR ARTIFICIAL ENTRIES in the books and records of Strømme Foundation are strictly prohibited. All offices and subsidiaries are required to make and keep books, records and accounts which, in reasonable detail, accurately and fairly reflect the transactions and disposition of the assets of Strømme Foundation. Consequently, all payments and other activities made pursuant to this Policy and implementing procedures must be accurately recorded inStrømme Foundation’s accounts in a timely manner and in reasonable detail. Examples of violations of this policy would include inaccurate employee expense reports which conceal the true purpose funds or the preparation and/or approval of false or misleading invoices from an implementing business partner.

NO POLITICAL, CHARITABLE CONTRIBUTIONS OR SPONSORSHIP can be made directly or indirectly, as this might be used as a subterfuge for bribery. The selection of new employees, implementing partners, or any agent or, representative or consultant (intermediary) who may be reasonably expected to act on behalf of Strømme Foundation shall be completed with due diligence.

THERE MAY BE INSTANCES WHERE PAYMENTS WILL NEED TO BE MADE to protect against loss of life, limb or liberty. These are called payments under duress and as such are permitted under the law, however the assumption is these are rare. Any payment or incident such as this must be reported to your line manager as a payment under duress and security procedures will be revised accordingly.


How can I report? ALTERNATIVES: SEND AN EMAIL TO: whistle-blow@stromme.org

MAKE CONTACT with the nearest SF office, and ask to talk to the person in charge.


on our webpages. Follow the link to whistleblowing on our webpage: www. stromme.org/contact us

How can I feel safe? No retaliation shall be taken against any employee who reports any suspected violation while acting in good faith. Supervisors or other employees who retaliate against whistle-blowers are in violation of this policy and consequently are subject to disciplinary action up to – and including – termination. Similarly the whistle blower has responsibility for their own actions and anyone making malicious deliberately false reports will also face disciplinary action.


What will happen?


Board members, employees, subsidiaries, and implementing partners should report any conduct among partners, regional office, microfinance companies or in head office which they believe in good faith to be a violation or apparent violation of this Policy.

An internal investigation will be launched by the head office or the regional office. After internal investigation, the regional director, international director and finance director will decide whether a forensic audit is needed. All corruption cases in the head office will be handled by the head office management and the external auditor. If the corruption or fraud concerns the regional office or microfinance companies, head office will in close relationship with the regional director, unless he/she is involved, investigate and follow up all related issues. If the corruption/fraud concerns a member of staff, the employee is immediately taken out on forced leave while the investigations are being performed. If the suspicions are confirmed, the employee’s contract will be terminated. In the case of suspected fraud or corruption within the partners, the relevant donors will be informed, the case will be internally documented, and the regional staff are responsible for follow up with the partner. All funding will be immediately suspended and if fraud or corruption is confirmed, appropriate action will be taken to recover the loss, to include legal action if needed. The decision to continue or terminate the partnership will depend on the attitude of the partner

organisations management/board and their ability/willingness to deal with perpetrators and strengthen internal controls. The investigation process should maintain objectivity, impartiality, and fairness and should be conducted with the highest levels of integrity. The investigation should be conducted expeditiously within the constraints of available resources. Investigative findings shall be based on facts and analysis, which may include reasonable inferences. The circulation of information regarding on-going investigations should be strictly limited to those with a need to know. The identities of parties providing testimony or evidence shall be treated with confidentiality. Staff are required to cooperate with an investigation and to answer questions and comply with requests for information. Strømme Foundation may engage external parties to assist in the investigation when that is deemed necessary. All documentation and information regarding open or closed cases, whether substantiated or unsubstantiated, shall be kept in a secure and confidential manner and shall be retained for at least ten years.


Purpose Strømme Foundation (SF) has a zero tolerance policy towards corruption . The purpose of this policy is to establish a supporting mechanism to SF’s anti-corruption program, and set forth the standards and procedures to be followed by SF’s employees at the head office, regional offices, microfinance companies, and implementing partners to prevent corruption and improper exchange in the conduct of business across all SF’s locations worldwide. This Policy applies to all SF employees (full time, part time, temporary and casual), and also to SF implementing partners, subsidiary companies, and those who access funds from SF.

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whistle-blow@stromme.org • www. stromme.org/contact us

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Transparent? Anti corruption policy and procedures (English)