Anti-Bribery and Fraud Policy

MAF attaches a high value to its ethical reputation and witness and is committed to all employees and agents of the charity acting fairly and with integrity in all dealings and relationships wherever we operate.

The MAF Board requires compliance with this policy in order to maintain the Charity’s good reputation and uphold MAF’s organisational values.

Definitions

a. Bribery is the practice of giving something (usually money) in order to influence the judgement or conduct of a person in a position of trust and thus gain an illicit advantage.

b. Extortion occurs when payment is demanded with threat intended (violence or otherwise).

c. Fraud is the use of deception with the intention of obtaining an advantage, avoiding an obligation, or causing loss to another party. It includes such acts as deception, bribery, forgery, extortion, corruption, theft, conspiracy, embezzlement, misappropriation, false representation, concealment of facts and collusion.

Scope

This policy applies to all MAF contracted, seconded and volunteer employees, national and international, whether based in programmes, or support offices or other locations. The term “employee” throughout this document therefore refers to anyone who works for MAF in any capacity.

Policy

a. MAF does not accept any level of fraud, bribery or corruption and expects all employees to work to the highest standards of honesty and integrity. Further, there is a requirement that any such activity is reported such that appropriate investigation and subsequent actions can be carried out.

b. MAF fully supports employees who are forced to pay illegal fees to avoid violent confrontation or personal injury [extortion].

c. MAF will only pay official fees for work carried out by government employees and will require a receipt for such payment. Payments are not permitted where it is intended to induce a person to perform a function improperly or be for a financial or other advantage to influence an official in their official role.

d. MAF will allow certain activities to assist in relationship building. These may include the giving of hospitality or gifts in appreciation of work carried out etc. The test of what is permitted is that of what a reasonable person in the UK would expect in relation to the performance of that function or activity.

e. MAF will seek to follow recognised procedures and timetables when processing any permissions, licences, renewals of documentation, inspections etc. so as to avoid being in a position whereby special favours or waivers have to be requested from government officials.

f. The Country Director will be responsible for approving any non-standard fees to government officials and will only authorise those that are clearly within this policy. To ensure transparency in such unusual circumstances, such non-standard payments will be clearly described in the MAF programme accounts.

g. MAF accepts that refusing to pay a bribe may mean delays in our programmes and even not being able to work in certain locations or countries.

h. All employees must recognise that paying a bribe will result in disciplinary action and possible loss of their job or position.

i. Training will be given to all employees on MAF’s anti-bribery policy with particular reference to dealing with situations where a bribe is requested or implied.

j. MAF will regularly monitor developments in the UK legislation, and in the OECD and Transparency International anti-bribery position and policies and seek to maintain parity.

k. MAF International’s Chief Finance Officer will advise a national MAF group when a confirmed incident of fraud has been investigated and finalised that relates to donations which have been sourced as restricted funds by that group.