OUR CORRUPTION, FRAUD AND WHISTLE BLOWING POLICY

MEET is committed to the highest standards of transparency and accountability to its stakeholders and as such maintains a zero tolerance to all forms of fraud and corruption. To this effect, all incidents of fraud and corruption will be reported and investigated. The Trust’s mission is to administer an endowment fund and other funds on behalf of the people of Malawi in order to provide sustainable support for improved environmental management activities. Any fraud or corrupt practise in MEET’s operations depletes resources intended for beneficiaries aligned to support MEET’s mission.

The Policy

  • The Corruption, Fraud and Whistle Blowing Policy is intended to clearly define fraudulent and corrupt actions; allocate responsibilities to manage and deter these actions; provide formal procedures to report fraud and corruption; and investigation guidelines to be followed when fraud or corruption is suspected.
  • MEET is committed to the highest standards of transparency and accountability to its stakeholders and as such maintains a zero tolerance to all forms of fraud and corruption. To this effect, all incidents of fraud and corruption will be reported and investigated.
  • The Trust’s mission is to administer an endowment fund and other funds on behalf of the people of Malawi in order to provide sustainable support for improved environmental management activities. Any fraud or corrupt practise in MEET’s operations depletes resources intended for beneficiaries aligned to support MEET’s mission.
  • Corruption and Fraud, in all its forms, can damage MEET’s reputation and diminish donor confidence in the Trust’s ability to operate in a transparent and accountable manner.
  • MEET staff are stewards of the endowment fund and are accountable for the effective and efficient use of MEET’s resources in accordance with other supporting policies such as the Conditions of Service, the Finance and Accounting Policy, the Procurement Policy and the Grant Disbursement Policy.
  • This policy applies to all activities and operations of MEET, including service providers and projects funded by MEET or by any other implementing partner.

Definition of Fraud

“Fraud is any act or omission that intentionally misleads, or attempts to mislead, a party to obtain a financial or other benefit or to avoid an obligation. Corrupt practices are generally understood as the offering, giving, receiving, or soliciting, directly or indirectly, anything of value to influence improperly the actions of another party. In this Policy, fraud is defined in a broader sense and includes, but is not limited to, theft, embezzlement, forgery and corrupt practices” (UNDP).

Definition of Corrupt practise

The offering, giving, receiving or soliciting of ant advantage to influence the action of any public officer or any official or any other person in the discharge of the duties of that public officer, official or other person (Corrupt Practises Act, Government of Malawi).

Corrupt and Fraudulent Actions

Corruption and Fraud includes but is not limited to the following:

  • Stealing or misappropriating funds and/or MEET assets
  • Forgery, falsification, alteration, destruction and/or unauthorised removal of documents, records and entries
  • Asking, offering and/or receiving cash, gifts or other benefits to improperly influence a procurement, recruitment or grant award process
  • Blackmail or extortion
  • Collusion with grant applicants, grantees, service providers and any other third party in exchange for preferential treatment or other benefits

Roles and Responsibilities

Board of Trustees and Board of Governors

  • MEET’s Board of Trustees, as custodians of the Trust’s assets, and MEET’s Board of Governors, as representatives of stakeholder interest groups, are responsible for the approval of the Corruption, Fraud and Whistle Blowing Policy and its subsequent revisions.
  • The Finance and Administration sub-committee of the Board will be responsible for setting up an Investigation committee tasked to review corruption and fraud allegations, to conduct an investigation of all available facts and to document an Incident Report for presentation to the MEET Board.
  • The Investigation committee shall comprise an independent MEET member of staff and an independent third party with relevant expertise and experience as the issue requires.

Executive Management

  • It is the responsibility of Executive Management to fully endorse and implement the Corruption, Fraud and Whistle Blowing Policy by taking active steps to detect and investigate corruption and fraud, to identify risks and any other improper activity, and maintain appropriate controls to prevent the recurrence of fraudulent activity or corrupt practise.
  • Executive Management is responsible for communicating the Corruption, Fraud and Whistle Blowing Policy to all employees, grantees and service providers, to raise awareness and to create an anti-fraud and corruption free culture.

All Employees

  • All employees are subject to MEET’s Conditions of Service; and fraud and corrupt practise constitutes a serious misconduct and may result in dismissal.
  • It is the responsibility of all employees to work in a professional manner and to maintain a level of integrity to prevent fraud and an individual obligation to report fraud in the workplace.

Corruption and Fraud Prevention

  • Appropriate measures will be taken by MEET to deter fraud and corruption in the workplace.
  • The Corruption, Fraud and Whistle Blowing Policy shall be disseminated to all MEET employees, Board Members, Grantees and service providers to create awareness and discourage acts of fraud.
  • MEET Management will frequently assess potential areas susceptible to corruption and fraud within the Trusts internal control systems and develop appropriate strategies to better detect, prevent and reduce risk.
  • Staff members are required to disclose potential situations where conflicts of interest may arise to maintain a clear distinction between private and professional relationships so as to avoid compromising the integrity of the organisation.

Reporting Corruption and Fraud

  • Staff Members are encouraged and obliged to report issues of suspected corruption and fraud as follows:
  • Support staff and Management staff will report to their immediate Supervisor. If they are not comfortable reporting to their immediate Supervisor, they will be at liberty to report to the next level of the Management hierarchy.
  • Executive Management staff shall report to the Chairperson of the Finance and Administration sub-committee.
  • All complaints should be as specific as possible and should include details of the wrongdoing, the persons involved and any other evidence to support the report.
  • Staff members should not contact the suspected individual(s) directly or discuss the issue with anyone outside of MEET other than the people listed above.

Confidentiality

  • MEET will endeavour to protect the identity of an individual making a complaint.
  • Participants in the investigation process may however be required to submit a full statement as part of the evidence.

Whistle Blowers

  • MEET upholds the practise of whistleblowing, as a means to prevent corruption and fraud, and will also strive to protect the identity of a whistle blower, in the instance that an incident is reported in good faith and is proven to be true.

Investigation Guidelines 

  • All instances of suspected corruption and fraud will be investigated, documented and reported.
  • The aim of the investigation is to establish the facts by reviewing documents and conducting interviews.
  • All the information and recommendations on the further actions to be taken pertaining to the investigation will be documented in an Investigation Report.
  • The Investigation Committee is responsible for presenting the Investigation Report to the Finance and Administration sub-committee of the MEET Board.
  • Every effort will be made by MEET to recover losses or wrongfully obtained assets.

Effective Date

  • This Corruption, Fraud and Whistle Blowing Policy is with effect from the 50th sitting of the MEET Board of Trustees and Governors at a meeting held on Friday 12th December 2014.
  • The policy will be reviewed every three years.