Anti-Fraud Policy
Aiming Change for Tomorrow
Approved in BOD Meeting held on 09 March 2024
Prepared by : Mr. Mubashir Banoori, Program Development Coordinator
Recommended by : Management Committee headed by CEO
Approved by : Board of Directors, ACT-International
Date:
Aiming Change for Tomorrow (ACT) International
Table of Contents
1 Vision, Mission, Values ............................................................................................................... 3
2 Mission ....................................................................................................................................... 3
3 Purpose of Antifraud policy ........................................................................................................ 5
4 Questions or Clarifications Related to This Policy ...................................................................... 7
Approval .......................................................................................................................................... 8
5 Acknowledgment ......................................................................... Error! Bookmark not defined.
Aiming Change for Tomorrow (ACT) International
ACT-International is a not-for-profit right based national organization focusing on women, youth,
children and marginalized segments of society. The organization particularly works with
disadvantaged segments of society to empower communities by building peoples engagement,
capacity and partnership focusing on women and children for better tomorrow. Organization
aims to develop partnerships and innovative programmes with the support of development
actors to contribute in the efforts of “Aiming Change for Tomorrow”. ACT-International is
registered as a non-profit organization under the Societies Registration Act, XXI of 1860.
1 Vision, Mission, Values
1.1 Vision
Aiming the world of opportunities for a better tomorrow.
2 Mission
Empowering communities to recover, progress and advance by building peoples` engagement,
capacity and partnership focusing women and children for a better tomorrow.
2.1 We pursue this mission through:
• Grassroots institutional development and networking with local civil society groups and
organizations;
• Sustainable economic development that integrates livelihoods, education, health,
infrastructure, environment, youth development, social cohesion and local leadership
management;
• Child development that integrates child rights, protection and improvement of service
provision to reduce neglect, abuse and exploitation;
• Partnerships with civil society and public sector organizations that promote
harmony and cohesion amongst development partners, integration of development
initiatives and accountability;
• Policy advocacy that integrates evidence based research on socio-economic
and political issues which are directly related to sustainable development of marginalized
communities especially women and children;
• Emergency relief services and recovery and rehabilitation initiatives that assist
people affected by conflict or disaster.
2.2 Our Core Values
• Our mission and humanitarian values impels us to act for a better tomorrow
• Participation for attaining ownership that leads to community empowerment
• Transparency for making humanitarian action accountable to stakeholders
Aiming Change for Tomorrow (ACT) International
• Equality for realizing the rights of disadvantaged and discriminated
• Innovation for achieving excellence to up-bring the lives of marginalized
• Responsibility for serving the underprivileged voluntarily
Aiming Change for Tomorrow (ACT) International
3 Purpose of Antifraud policy
The purpose of this document is to communicate ACT’s policy regarding the deterrence
and investigation of suspected misconduct and dishonesty by employees and others, and
to provide specific instructions regarding appropriate action in case of suspected
violations.
3.1 Definition of Misconduct and Dishonesty
This policy of misconduct and dishonesty includes but is not limited to:
• acts which violate ACT’s Code of Conduct
• theft or other misappropriation of assets, including assets of ACT, ACT’s
guests, tenants, suppliers or others with whom we have a business
relationship
• misstatements and other irregularities in company records, including the
intentional misstatement of the results of operations
• wrongdoing
• forgery or other alteration of documents
• fraud and other unlawful acts
• any similar acts.
ACT specifically prohibits these and any other illegal activities in the actions of its
employees, managers, executives and others responsible for carrying out the agency’s
activities.
3.2 Policy and Responsibilities
Reporting
It is the responsibility of every employee, supervisor, manager and executive to
immediately report suspected misconduct or dishonesty to their supervisor or the Chief
Executive Officer if the supervisor is involved, or the Board President if the Chief
Executive Officer is involved. Supervisors, when made aware of such potential acts by
subordinates, must immediately report such acts to the Chief Executive Officer. Any
reprisal against any employee or other reporting individual because the individual, in
good faith, reported a violation is strictly forbidden.
Due to the important yet sensitive nature of the suspected violations, effective
professional follow up is critical. Managers, while appropriately concerned about “getting
to the bottom” of such issues, should not in any circumstances perform any investigative
or other follow up steps on their own. All relevant matters, including suspected but
unproved matters, will be referred immediately to ACT’s auditor and attorney.
Aiming Change for Tomorrow (ACT) International
To facilitate reporting of suspected violations, especially in those situations where the
reporting individual wishes to remain anonymous, ACT will receive anonymous reports
of suspected fraud by calling either the Chief xecutive Officer or Chief Strategical
Officer.
Additional Responsibilities of Supervisors
All employees have a responsibility to report suspected violations. However, employees
with supervisory and review responsibilities at any level have additional deterrence and
detection duties. Specifically, personnel with supervisory or review authority have three
additional responsibilities.
First, you must become aware of what can go wrong in your area of authority.
Second, you must put into place and maintain effective monitoring, review and
control procedures that will prevent acts of wrongdoing.
Third, you must put into place and maintain effective monitoring, review and
control procedures that will detect acts of wrongdoing promptly should prevention
efforts fail.
Authority to carry out these three additional responsibilities is often delegated to
subordinates. However, accountability for their effectiveness cannot be delegated and
will remain with supervisors and managers.
Assistance in effectively carrying out these responsibilities is available upon request from
the Chief Executive Officer or his/her designee.
Responsibility and Authority for Follow Up and Investigation
The Chief Executive Officer has the primary responsibility for all investigations
involving the organization. The Chief Executive Officer may request the assistance of an
independent auditor in any investigation, including the evaluation of internal controls.
Properly designated members of the investigative team will have:
• free and unrestricted access to all agency records and premises, whether
owned or rented
• the authority to examine, copy and/or remove all or any portion of the
contents of files, desks, cabinets, and other storage facilities (whether in
electronic or other form) without the prior knowledge or consent of any
individual who might use or have custody of any such items or facilities when
it is within the scope of investigative or related follow up procedures.
All investigations of alleged wrongdoing will be conducted in accordance with applicable
laws and agency procedures.
Aiming Change for Tomorrow (ACT) International
Reported Incident Follow Up Procedure
Care must be taken in the follow up of suspected misconduct and dishonesty to avoid
acting on incorrect or unsupported accusations, to avoid alerting suspected individuals
that follow up and investigation is underway, and to avoid making statements which
could adversely affect the agency, an employee, or other parties.
Accordingly, the general procedures for follow up and investigation of reported incidents
are as follows:
1. Employees and others must immediately report all factual details as indicated
above under Policy.
2. The Chief Executive Officer has the responsibility for follow up
and, if appropriate, investigation of all reported incidents.
3. All records related to the reported incident will be retained wherever they
reside.
4. Do not communicate with the suspected individuals or organizations about the
matter under investigation.
5. The Chief Executive Officer may also notify the auditor of all reported
incidents so that it may be determined whether this matter should be brought
to the attention of the Board of Directors.
6. The Chief Executive Officer may also obtain the advice of an attorney at any
time throughout the course of an investigation or other follow up activity on
any matter related to the report, investigation steps, proposed disciplinary
action or any anticipated litigation.
7. Neither the existence nor the results of investigations or other follow up
activity will be disclosed or discussed with anyone other than those persons
who have a legitimate need to know in order to perform their duties and
responsibilities effectively.
8. All inquiries from an attorney or any other contacts from outside of ACT
including those from law enforcement agencies or from the employee under
investigation, should be referred to ACT’s attorney.
Investigative or other follow up activity will be carried out without regard to the
suspected individual’s position, level or relationship with ACT.
4 Questions or Clarifications Related to This Policy
All questions or other clarifications of this policy and its related responsibilities should be
addressed to the Chief Executive Officer, who shall be responsible for the administration,
revision, interpretation, and application of this policy.
Aiming Change for Tomorrow (ACT) International
Approval
The Board of Directors approved the Anti-Fraud Policy of Aiming Change for Tomorrow-
International with additions and revisions under Agenda item no in the BOD Meeting held
on 09 March 2024
