Anti-Corruption and Integrity Policy and Procedures
Summary
FSD Africa maintains a "zero tolerance" policy toward fraud and corruption, applying these standards to all directors, employees, consultants, and funding recipients. The policy defines sanctionable practices—including corrupt, fraudulent, collusive, coercive, and obstructive practices—and mandates a framework for reporting and investigation. It establishes the role of an Investigative Officer, typically the Chief Operating Officer, to conduct impartial inquiries and report findings to the Chair. Additionally, the document outlines strict Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) controls, emphasizing 'Know-Your-Client' (KYC) protocols, enhanced due diligence for Politically Exposed Persons (PEPs), and the screening of counterparties against international blacklists.
Key insights
- FSD Africa defines five specific 'Sanctionable Practices': corrupt practices (improperly influencing actions), fraudulent practices (misleading for benefit), collusive practices (improper arrangements between parties), coercive practices (harming property to influence actions), and obstructive practices (impeding investigations or audit rights).
- The organization mandates a reporting structure where allegations of fraud and corruption must be reported immediately to the FSDA Director, or to the DFID fraud team ([email protected]) if the Director is involved. The Chair must then inform the Board and other relevant funders within five days.
- Investigations are led by a nominated Investigative Officer, usually the Chief Operating Officer, who reports to the Chair. This officer is responsible for maintaining objectivity, conducting independent inquiries, and preparing an annual report for the Board.
- FSD Africa implements a 'Know-Your-Client' (KYC) principle for all funding and investments, requiring the identification of beneficial owners and the use of enhanced due diligence for Politically Exposed Persons (PEPs).
- The policy prohibits engagement with individuals or entities listed on internationally recognized blacklists, such as those from the UN Security Council, US Department of Treasury, HM Treasury, EU, World Bank, and Interpol.
- The organization requires an annual written confirmation by January 31st stating that it and its affiliates have not engaged in activities prohibited by UN Security Council resolutions under Chapter VII of the UN Charter and are not involved with sanctioned parties.
- Whistleblowers are protected from retaliation, and any such retaliation is treated as a separate act of misconduct.
Cite the original document
- APA
- FSD Africa (2015). Anti-Corruption and Integrity Policy and Procedures. https://fsdafrica.org/wp-content/uploads/2025/05/15-12-03-FSDA-Anti-corruption-and-Integrity-Policy.pdf
- Chicago
- FSD Africa. Anti-Corruption and Integrity Policy and Procedures. 2015. https://fsdafrica.org/wp-content/uploads/2025/05/15-12-03-FSDA-Anti-corruption-and-Integrity-Policy.pdf.
- Wikipedia
- {{cite report |author=FSD Africa |title=Anti-Corruption and Integrity Policy and Procedures |date=3 December 2015 |url=https://fsdafrica.org/wp-content/uploads/2025/05/15-12-03-FSDA-Anti-corruption-and-Integrity-Policy.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
- BibTeX
- @techreport{fsdafrica2015anticorruption, author = {{FSD Africa}}, title = {{Anti-Corruption and Integrity Policy and Procedures}}, institution = {FSD Africa}, year = {2015}, month = dec, url = {https://fsdafrica.org/wp-content/uploads/2025/05/15-12-03-FSDA-Anti-corruption-and-Integrity-Policy.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }
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