Anti-Fraud, Anti-Corruption & Whistleblower Policy

1. Purpose and scope

This policy sets out how we prevent fraud, bribery, corruption and conflicts of interest. It applies to trustees, staff, volunteers, interns, consultants, contractors, vendors and anyone acting on behalf of the Foundation.

2. Key definitions

Fraud

Intentional deception or dishonest conduct for personal or organisational gain, including misappropriation, false invoices, forged records or expense manipulation.

Bribery

Offering, promising, giving, requesting, accepting or agreeing to receive money, gifts or anything of value to influence a decision improperly.

Kickback

A payment or benefit given in return for preferential treatment, procurement or a contract.

Conflict of interest

A situation where a personal, family, financial or other interest could improperly influence a decision.

3. Prohibited conduct

• Offering, giving, requesting or accepting bribes, kickbacks or facilitation payments.
• Using Foundation funds, property or information for personal benefit.
• Falsifying invoices, receipts, expense claims, donation records or financial reports.
• Approving a transaction in which you or a related person has an undisclosed interest.
• Accepting gifts, hospitality or benefits that could influence a decision.
• Destroying, concealing or altering records to obstruct an investigation.
• Retaliating against someone who reports a concern in good faith.

4. Gifts and hospitality

We do not offer or accept gifts, hospitality or entertainment that could influence a decision, create an obligation or appear improper. Modest, lawful and infrequent hospitality may be accepted with disclosure and approval. Cash and cash equivalents are never acceptable. We keep a register of gifts and hospitality above a reasonable threshold.

5. Financial controls

• Funds are held in the Foundation’s own bank account and are not mixed with personal accounts.
• Payments require appropriate authorisation, with dual approval for larger transactions.
• Duties are separated so that the person who approves a payment is not the same person who records or reconciles it.
• Cash payments are avoided wherever possible and, where used, are recorded and receipted.
• Bank reconciliations and financial reports are reviewed regularly.
• Supporting documents are kept for every expense and donation.
• Books and records are kept accurately and retained for the required period.

6. Procurement and vendors

We will select vendors on merit, compare reasonable alternatives where appropriate, document the basis for significant decisions and avoid dealing with vendors connected to decision-makers without disclosure and approval. Vendors must not offer inducements, and we will take action if they do.

7. Conflicts of interest

Trustees, staff and volunteers must disclose any personal, family, financial or other interest that could conflict with their duties. Disclosures should be made in writing to the Grievance Officer or the governing body as soon as practicable.

A person with a conflict must not participate in discussion, voting or decision-making on the matter. The disclosure and recusal will be recorded in the minutes.

8. Related parties

The Foundation is a shareholder of Arkynox, which maintains the Sangathya journal platform. Any transaction with Arkynox or another related party must be on fair and arm’s-length terms, disclosed to the governing body, approved without the interested person voting and reported in our financial disclosures.

9. Whistleblowing

Anyone may report suspected fraud, corruption, abuse of authority, safeguarding failure or other serious wrongdoing. Reports can be made to the Grievance Officer or, if the concern involves the Grievance Officer, to a trustee.

We accept reports in writing, by email or through another reasonable channel. You may report anonymously, although anonymity may limit our ability to investigate or update you. We will keep your identity confidential to the extent possible and lawful.

10. Investigation

We will assess every report promptly, decide whether an investigation is needed and appoint an impartial person or committee. Investigations will be proportionate, documented and conducted with respect for the rights of everyone involved. We may suspend access or duties temporarily where necessary to protect people, funds or evidence.

11. No retaliation

We will not tolerate retaliation, victimisation or unfair treatment against anyone who reports a concern in good faith or participates in an investigation. Deliberately false or malicious allegations may themselves be treated as misconduct.

12. Consequences and recovery

Substantiated wrongdoing may lead to disciplinary action, termination of a volunteer or vendor relationship, recovery of funds, referral to the police or other authorities, and civil action where appropriate. We will cooperate with lawful investigations.

13. Review and contact

We review this policy periodically. Concerns may be sent to contact@sangathya.org. Our Grievance Officer is yet to be appointed. Postal address: Registered address will be published once registration is complete.