Fraud and corruption prohibition
Bribery, theft, forgery, collusion, hidden commissions, inflated prices or beneficiary counts, money laundering and financing unlawful activities are prohibited. Do not invent data, invoices, quotations, certificates or project histories. Attribute founders’ previous work to the individuals and capacities involved; do not present it as the organisation’s institutional record without evidence.
Interests and gifts
Decision-makers disclose family, financial, employment or expected-benefit interests involving an applicant, supplier or partner before decisions. Record the interest and remove the person from evaluation and approval, assigning an authorised unconflicted decision-maker. Cash gifts and benefits that influence decisions are prohibited; modest hospitality or tokens require recording under written controls. Office does not confer preference in assistance or procurement.
Procurement and evidence
Start with a documented need, verifiable specification, budget and approval authority. Obtain independent comparable offers and assess quality, safety, suitability, warranty and total cost. For DAP, provide the required product quotations, including at least two where the programme requires them. Do not split purchases to avoid approval controls. Document the reason and authorisation for any exceptional direct purchase. Retain requests, bids, evaluation, contract, receipt, invoice, payment and asset records.
Financial separation and records
Keep organisational funds separate from personal and other entities’ accounts. Under bylaw Article 42, expenditure and transfers require the Chair or Deputy Chair together with the Treasurer; no person may approve, execute and audit the same expenditure. Reconcile accounts, check assets and review access when roles change. Retain financial records for at least five years or longer where law or agreement requires, and obtain audit when applicable requirements trigger it. These are controls, not a claim that a bank account or completed audit already exists.
Counterparty and funding checks
Verify supplier and partner identity, funding sources, signing authority and receiving account. Check applicable sanctions, counter-terrorism restrictions and donor requirements before contracting and payment. Reject anonymous-source funding or conditions that compromise independence or breach law. An application or publication does not prove completed registration; disclose the status and obtain required documents before commitments that require them.
Reporting and response
Use the complaints channels, preserve evidence and exclude conflicted decision-makers. Notification must not wait for proof. Report suspected or actual fraud or corruption to DFAT within the contractual period; where its general toolkit period applies, within five working days, notifying the agreement manager and using fraud.corruption@dfat.gov.au. Assess fairly and take appropriate loss-prevention, recovery and referral action without retaliation.
Document control
Policy owner: Board of Directors, under Article 53 of the approved internal bylaws. Review at least annually and after significant changes. Arabic and English versions are equivalent; resolve any ambiguity without weakening protection.
Official references used in preparation: