Policies
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Anti-Fraud and Anti-Corruption
Last updated:
Glossary
Term | Definition |
Bribery | Offering, promising, giving, accepting, or soliciting of an advantage as an inducement to do something which is illegal or a breach of trust. The purpose of the bribe is to ‘induce a person to perform a relevant function or activity improperly or to ‘reward a person for the improper performance of such a function or activity. Bribery includes facilitation payments, favours and kickbacks. |
Company | Dhamana Guarantee Company Limited. |
Corruption | The abuse of power for private gain. Corrupt activities are broad and encompass acts such as Fraud, Theft, Bribery, nepotism or favouritism. |
Extortion | Is obtaining a benefit through coercion (for example threats of future physical injury, property damage or exposure to criminal charges or public humiliation) or an implicit or explicit threat to give the payer a worse than fair treatment. |
Fraud | Is an intentional act or omission intended to deceive another party that may cause the party to obtain an advantage improperly, avoid an obligation or cause loss to another party. Examples of fraudulent acts include deliberately giving false information in a resume or report, forgery, fabrication of documents or acting under false pretenses |
Personnel | The employees, executive and non-executive directors, committee members, volunteers, interns, consultants and contractors of the Company; |
Recipients | persons and entities which receive funding from the Company either directly or indirectly or benefit from the Company’s guarantees. |
Service Providers | Third-party service providers responsible for delivering the core activities of the Company; |
Suspicion | Is a reasonably held belief or feeling that something is likely or has happened. |
Theft | Where one dishonestly takes or uses property belonging to another, without consent and with the intention of permanently depriving the other of it. An example could be a deliberate refusal to return the Company’s assets after leaving. |
Policy Statement
The Company is committed to conducting its business, upholding the highest ethical standards and good governance and has adopted zero tolerance to Bribery, and Corruption. It is a criminal offence to offer, promise, give, request or accept a bribe. Failure to address the risk of corruption and Bribery may undermine the Company’s reputation and lead to fines and/or other penalties for the Company and/or individuals.
The Company does not engage in Corruption and does not pay Bribes. The Company’s position on Corruption is clear; the offer, payment, authorisation, solicitation and acceptance of bribes and other improper advantages is unacceptable.
The Company takes all reported suspicions of Fraud and Corruption seriously and commits to responding to them adequately, promptly and effectively. The Company may consider a breach of the provisions of this Policy to be a disciplinary matter.
The Company is committed to acting professionally, ethically, fairly and with integrity in all dealings with public or private persons.
Prohibited Practices
Facilitation Payments: Small, unofficial payments made to expedite routine administrative tasks are prohibited.
Kickbacks: Payments made in return for a business favour or advantage are prohibited.
Donations: The Company does not make contributions or donations to political parties. Charitable donations must not be made to gain any advantage.
Reporting Fraud & Corruption
The Company is committed to preventing and identifying Fraud and Corruption in its programmes, through raising awareness of Fraud risks, implementing controls aimed at preventing and detecting Fraud and Corruption, and enforcing this policy. The Company, therefore, implements the following pillars of prevention.
Top-level commitment –The Company commits to oversee this zero- tolerance policy and the implementation of adequate controls to safeguard the Company’s assets, stocks and funds from abuse.
Risk assessment – the Company will adopt a risk-based approach to tackling Fraud and Corruption in its programmes. The risk of Fraud and Corruption in its programmes will be identified and communicated to relevant stakeholders together with an assessment of the extent to which the risks can be mitigated. The risk of Fraud and Corruption will be considered during the design of programmes. It will be monitored and reported as part of the Company’s risk management framework.
Effective anti-fraud and corruption policies and procedures - The Company will put in place procedures that are effective and proportionate to the risks identified, circumstances and culture. These procedures will include those designed to prevent and those designed to detect the risk of fraud.
Due diligence and procedures for third parties – The Company shall employ a fair and proportionate due diligence process for Service Providers and Recipients before entering contracts. The level of due diligence will be based on risk and will be done in line with the Company’s due diligence policy.
Communication and training – the Company will employ a robust continuous system of building awareness and understanding of its anti-fraud and anti-corruption procedures and systems. Service Providers and Recipients will be informed of the expectations laid out in this Policy, which will also form part of the contractual conditions. Training for Service Providers, Recipients and associated third parties will be conducted by the Company on a case-by-case basis in line with the risks identified and capacity assessment outputs.
It is mandatory for all Personnel to report suspicions of Fraud or Corruption immediately. Suspicions must be reasonably held but do not require any proof before making a report.
Personnel who have a Suspicion may first report it to their line manager. Service Providers, Recipients or third parties associated with the Company may first report Suspicions to the manager who holds their contracts. Should the Personnel feel, the line manager might be involved or will not take the Suspicion seriously, they should report it directly to the Legal & Compliance Manager (LCM).
Where a Suspicion, involves the LCM, they may, report it to the Chief Executive Officer (CEO). If the CEO is involved, then the report must be made to the Chair of the Board.
Personnel, Service Providers, Recipients and any third party may also report suspicions directly to the LCM by sending an email to: transparency@dhamana.com
Fraud in grantees
Recipients must have proportionate procedures to mitigate the risk of Bribery, Fraud and/or Corruption in the programmes funded by the Company. This means the procedures instituted should take into account the Bribery, Fraud and Bribery risk faced by the Recipient. the Company will make an assessment of these risks during the due diligence process.
Where a Recipient suspects that an act of Bribery, Fraud or Corruption has occurred, which relates to the funds of the Company or persons working on the Company’ projects, then they must report it within 48 hours to the Company.
The requirement to comply with this Policy will form part of the Company’s and its grantees’ contractual obligations.
