General Purchasing Conditions

General Purchasing Conditions

Content

General Purchasing Conditions .............................................................................................................................. 0

Content ..................................................................................................................................................................... 1
Article 1: Purpose and scope .......................................................................................................................... 2
Article 2: Order ................................................................................................................................................... 2
Article 3: Price, invoicing and payment ........................................................................................................ 2
Article 4: Packaging ........................................................................................................................................... 3
Article 5: Delivery ............................................................................................................................................... 3
Article 6: Transport, receipt of goods and transfer of ownership ..................................................................... 3
Article 7: Delivery deadlines and penalties for late delivery ............................................................................... 3
Article 8: Modifications and substitutions .................................................................................................. 3
Article 9: Duration ............................................................................................................................................. 4
Article 10: Quantities ........................................................................................................................................ 4
Article 11: Warranties ....................................................................................................................................... 4
Article 12: Intellectual property and confidentiality .............................................................................................. 5
Article 13: Liability and insurance ................................................................................................................. 5
Article 14: Sub-contracting ............................................................................................................................ 5
Article 15: Ethics ................................................................................................................................................ 5
Article 16: Resolutory clause .......................................................................................................................... 6
Article 17: Force majeur .................................................................................................................................... 7
Article 18: Law applicable to the settlement of disputes ..................................................................................... 7
Article 19: Jurisdiction clause ......................................................................................................................... 7

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 General Purchasing Conditions

Article 1: Purpose and scope

These General Purchasing Conditions are applicable to supply contracts and, more generally, to any act of purchase
of moveable goods by HANDICAP INTERNATIONAL (hereinafter referred to as HI) with companies, suppliers or their
sub-contractors.
If the co-contracting party (hereinafter referred to as the Supplier) has its own general terms and conditions of sale, it
undertakes to forward them to HI at the commercial negotiation stage, prior to the conclusion of the final sales contract.
In the absence of transmission, by the Supplier, of its own general terms and conditions of sale, these General
Purchasing Conditions shall constitute the sole basis for commercial negotiations and the reference document for the
administrative and financial management of the contract of sale.
In the event of any incompatibility between the general terms and conditions of sale of the Supplier and these General
Purchasing Conditions, the parties undertake to negotiate the incompatible aspects in good faith and, where there is
agreement, to incorporate them in writing into the final contract of sale.
The Supplier declares to have read the present General Purchasing Conditions and to accept them in their entirety.
The Supplier acknowledges that these conditions form an integral part of the final contract of sale.
In the event of a discrepancy between the general conditions and any special conditions included in one or more of
the contractual elements established between HI and the Supplier as a component of the contract of sale, the latter
shall prevail over the former.

Article 2: Order
The Supplier shall confirm its intention to comply with the Purchase Order and the General Purchasing Conditions by
returning to HI an acknowledgement of receipt containing the identical conditions within two (2) calendar days of
receipt of the said Purchase Order.
To this end, the parties agree that acknowledgement of receipt may be constituted by return of the Purchase Order
and its General Purchasing Conditions, with the sections concerning the Supplier duly completed in a legible and
unambiguous manner, and the document signed on the front and back.
The parties must come to a prior agreement on whether the return of the Purchase Order and its General Purchasing
Conditions should be made by post, email or hand-delivery.
The purchase and, a fortiori, the order, shall be considered final on the date of receipt by HI of this acknowledgement
of receipt, and within the specified time limit.
After this time limit, HI shall be entitled to retract its offer and to cancel its order, which shall then be considered null
and void.
In order to be valid, the Supplier's adherence to HI's offer shall correspond in all respects to the procedures required
by HI.
In the present case, the contractual elements, which are an integral part of the overall agreement between HI and the
Supplier, are (set out in function):
- HI’s purchase order:
- These General Purchasing Conditions;
- The Supplier’ price proposal (estimate, quotation or call for tenders);
And where applicable:
- The Supplier’s General Terms and Conditions of Sale;
- The contract or framework agreement;
- Any specific conditions applicable to the order;
- HI’s schedule;
- HI’s specifications or technical clauses for the contract;
- HI’s plans relative to the contract;
- The plans or technical specifications relative to the price proposal.

Article 3: Price, invoicing and payment

The prices are mentioned by the Supplier on its price proposal that take the form of an estimate, a pro forma invoice,
a quotation or a call for tenders. Once accepted, they become firm and are not modifiable.
In the absence of any other negotiated and agreed provision, the terms of payment are 100% by draft or bank transfer
at 30 days end of month from receipt of invoice, subject to actual delivery of the products stipulated in the contract.

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 General Purchasing Conditions

Article 4: Packaging
The Supplier shall deliver the products in the appropriate packaging, taking into account the nature of the products
and taking all measures to protect the products from bad weather, corrosion, loading accidents, transport or storage
risks, vibrations or shocks.
Products shall be sealed, packaged, marked and otherwise prepared for transport in a manner that is in accordance
with good commercial practice, acceptable to common carriers for transport at the lowest rates and adequate to insure
safe arrival of the supplies at destination.
The Supplier shall be considered solely responsible for any damage to the products or any extra expenses due to
incorrect or inadequate packaging, marking or labelling, detected at the time of delivery - or afterwards, if it could not
be detected at that time, except for damages or expenses due to special packaging, marking or labelling instructions
required by HI.

Article 5: Delivery
The parties have agreed that all deliveries shall be made in accordance with Incoterms® 2020, and during the business
hours specified on the purchase order.

Two supplier delivery slips shall be drawn up, one to be sent to HI directly on the day the order is sent, and the other
to accompany the merchandise. Supplier delivery slips shall contain the full purchase order reference and the product
description, quantity, gross weight (with packaging), net weight (without packaging) and supplier reference.

.
Article 6: Transport, receipt of goods and transfer of ownership
The transfer of ownership shall be effective on the date of delivery of the products to the destination address
specified on the order form.
For the interpretation of these General Purchasing Conditions and its related clauses, the parties agree to apply the
latest version of Incoterms® 2020.

Article 7: Delivery deadlines and penalties for late delivery

Delivery times are specified in the Supplier’s price proposal and on the front page of the Purchase Order. They are
firm and may not be revised.
The Supplier's acceptance of the sale and purchase order constitutes an irrevocable undertaking to meet the agreed
delivery deadlines.
In the event of early delivery, the supplier shall not be entitled to a bonus.
If the deadlines are not met, the parties acknowledge HI’s right to ask for a price reduction proportional to the price of
the order.
After having served formal notice on the Supplier to apply this reduction, and if the Supplier remains in default, HI
reserves the right to apply late delivery penalties as from the fifteenth calendar day after the expiry of the contractual
delivery period.
These penalties are set at 0.5% of the total amount of the price of the order per calendar day of delay, up to a maximum
limit of 7% of the said amount.
After the thirtieth calendar day of delay, the parties acknowledge that HI may cancel the order without further formality
and terminate the contract without further notice to the Supplier.
Neither of these actions to reduce and terminate the contract shall prevent HI from seeking compensation for the
prejudice(s) suffered due to a delay attributable to the Supplier.

Article 8: Modifications and substitutions

Any modifications desired by one of the parties to the services provided for in the contract must imperatively be notified
to the other, detailed, quantified if necessary, and expressly accepted before they become binding on the parties and
can be implemented.

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 General Purchasing Conditions

Any modifications agreed to by the parties must necessarily be formalized in writing within fifteen (15) calendar days
by the drafting of an amendment to the contract.
The prices indicated by the Supplier in its offer and agreed to by HI are fixed for the duration of the contract of one (1)
year from the date of signature of both parties. At the end of this period, if the parties intend to renew the contract of
sale, they can renegotiate in good faith the tariffs applied by the Supplier, and may agree, if necessary, on indexing
them to market prices.
At the initiative of one of the two parties, equivalent goods may be proposed in substitution for those agreed at the
signing of this contract. The quantity, quality and use that HI can derive from them, as well as the price, must remain
the same.
No changes to the nature of the goods delivered may be made without HI's express and written consent. In accordance
with the chosen Incoterms®, the parties agree that the price covers carriage and unloading at the delivery address.
The price therefore includes all the costs to be borne by the supplier, specifically: packaging, labelling, packing,
transport, loading, insurance, unloading of goods.

Article 9: Duration
The parties acknowledge that the contract of sale and all of contractual elements constituting it shall come into force
and take full effect on the date of signature by the parties of the Supplier Purchase Order and its General Purchasing
Conditions which are an integral part of it.
The parties agree that the contract of sale is concluded for a fixed term of one (1) year from the date of signature. They
acknowledge that under no circumstances may it be tacitly renewed.
However, they may agree to its extension for a specific term by expressly indicating their willingness to do so before
the expiry of the initial term.

Article 10: Quantities

The parties have agreed on the quantities to be delivered by the Supplier. These quantities should appear on the
Purchase Order.
Consequently, HI shall only pay for the quantities ordered and reserves the right to refuse any delivery in excess of
the order.
Any return of the surplus will be at the exclusive expense, risk and peril of the Supplier.

Article 11: Warranties

The Supplier undertakes to provide HI with all useful information concerning the use of the goods, and to warn HI of
any risks associated with the products, in particular with regard to hygiene, safety and any other type of danger.
The Supplier guarantees HI against eviction, of its own doing and that of third parties. In this respect, it guarantees
that HI is entitled to fully dispose of the goods, which must not be the subject of any legal dispute, and that no rights in
rem exist against them at the time of the conclusion of the sale.
The Supplier shall comply with all laws, regulations, prescriptions and good practices applicable to the goods
concerned, in particular with regard to production, manufacture, packaging, repair, pricing and delivery, in such a way
that the products can be legally bought, sold, transported or exported.
The Supplier guarantees, for a minimum period of twelve (12) calendar months from the acceptance of the products
by HI, that these products shall be free from defects, latent defects, contamination and abnormal wear and tear of any
kind, even apparent.
During the entire conventional warranty period, HI shall notify the Supplier in writing of any defect or malfunction of the
products and the Supplier, once served notice, shall, at its own expense and within a period of fourteen (14) calendar
days from the date of receipt of said formal notice, either replace or repair the products or correct the defect or
malfunction. Any replacement or repair of a product under warranty shall give rise to a new warranty for a minimum
period of twelve (12) calendar months from the acceptance by HI of the replaced or repaired product.
Beyond this period, if the supplier does not comply with its obligation to replace, repair the goods, or correct the defect
or malfunction, HI shall be entitled, at its sole discretion, either to carry out the replacement, repair or correction of the
goods itself, including through recourse to a third party, at the supplier's sole expense, or to obtain from the Supplier
a full refund of the purchase price of the defective goods.
The Supplier guarantees the supply of all the spare parts necessary for the proper functioning of the products, as well
as after-sales service for a minimum period of three (3) years from the date of delivery.

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 General Purchasing Conditions

The Supplier acknowledges that the warranties specified above are in addition to any legal guarantees and those
expressly granted by the Supplier, other than those stipulated here, as well as any other guarantee, express or tacit,
applicable to the corresponding order.

Article 12: Intellectual property and confidentiality

The Supplier guarantees that the products to be supplied do not infringe any patents, licenses, industrial patent rights,
copyrights, trademark rights or any other industrial and/or intellectual property rights of any third party. Where
applicable, the Supplier guarantees that it is the owner of all rights and authorisations to use, manufacture and sell the
products and that HI will thus have full rights over the products purchased, including exploitation of the rights.
Otherwise, the Supplier undertakes to defend HI against any claim or action for infringement of intellectual or industrial
property rights belonging to a third party and, in this respect, to pay all costs incurred by HI for its defence against any
such claim or action, including a reasonable amount of legal fees. The Supplier may also be required to pay
compensation for any damage, loss or prejudice suffered by HI and arising directly or indirectly from this claim or
action.
Any data, drawings, designs, equipment or other material or information that is provided by HI or provided by the
Supplier but paid for by HI as a part of the products' purchase price, shall be the sole property of HI and shall be
considered confidential information belonging exclusively to HI which the Supplier undertakes not to disclose.
The Supplier agrees to keep strictly confidential any materials and/or information belonging to HI and received for the
purposes hereof and not to communicate or disclose such material and/or information to any third party, including its
own employees, without HI's prior written consent. Any written or oral communication or any publication concerning
the order or its contents shall be subject to HI's prior written consent.

Article 13: Liability and insurance

The Supplier shall be considered solely and civilly liable to HI and any third party for any damage to property or persons,
whether material, bodily or moral, arising from the performance by the Supplier or the Supplier's employees, agents or
subcontractors of the Supplier's obligations under the purchase order.
The Supplier shall take out adequate insurance to cover the consequences of any liability that, in accordance with the
stipulations outlined in the above clause, may be incurred vis-à-vis HI, and hereby agrees to defend and indemnify HI
against any damages and other consequences for which it is liable.

Article 14: Sub-contracting

Only first level subcontracting is authorised. Consequently, a subcontractor may not subcontract the performance of
the contract.
A contractor may subcontract all or part of the contract under certain restrictive conditions:
- any subcontracting must be declared by the Supplier, future contractor, when submitting the price proposal and must
be authorised by HI before the contract is executed.
- Any subcontracting shall be the subject of a specific written agreement between HI and the Supplier for the purpose
of determining the division of responsibilities, obligations and tasks in the performance of the operation between the
Supplier and its subcontractor;
- The Supplier, as the contractor, shall ensure that its subcontractor complies with the confidentiality clause that exists
between it and HI;
- The Supplier, as the contractor, shall ensure that its subcontractor complies with the obligations incumbent upon it
and determined by the parties to the main contract.
Failure to comply with any of these provisions may result in the termination of this contract.

Article 15: Ethics

HI is committed to combatting fraud, corruption, economic and sexual exploitation, abuse and harassment of children
and vulnerable adults benefiting from or impacted by HI's intervention. HI implements risk reduction measures in its
programmes, with zero tolerance for such abuse and the application of a victim-centred approach.

By signing these General Purchasing Conditions, the Supplier certifies that:

- It is not involved in any corrupt or fraudulent practices

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 General Purchasing Conditions

- It is not in a conflict of interest with HI representatives

- It respects existing laws on the non-exploitation of children and vulnerable adults,
- It complies with social welfare rights, notably minimum wage and working hours
- It respects the basic working conditions, in particular the exclusions of any physical constraints or sanctions and
the guarantee of the safety of its employees
- It does not participate in any way whatsoever in the propagation of anti-personnel landmines (production, trade,
property, shares, transport, storage, etc.)
- It does not participate in any way whatsoever in the arms trade (production, trade, property, shares, fund-raising,
transport, storage, etc.)
- It does not have ties of any nature with any kind of terrorist network (acts of violence perpetrated by an organisation
against civilian populations or installations).
- It will endeavour to use production techniques and processes that comply with fundamental regulations on the
protection of the environment (principally with respect to deforestation and the use of chemical agents affecting
biodiversity)

The Supplier acknowledges and agrees to comply with the following HI policies (accessible: https://hi.org/fr/politiques-
institutionnelles): Protection of Beneficiaries from Sexual Exploitation and Abuse, Child Protection, Prevention of
Fraud and Corruption , Disability, Gender and Age Policy and the HI Code of Conduct.
If you believe that the action of a person (or group of persons), belonging to HI, does not comply with the above rules,
you should report it in accordance with procedure by contacting HI using the following link: https://hi.org/fr/formulaire-
signalement
HI reserves the right to use international supplier screening tools to check the Supplier’s history and potential
involvement in illegal or unethical activities.
HI wishes to limit the impact of its interventions on the environment and expects a similar approach from its suppliers
and service providers.Failure to comply with any of the above obligations may result in the automatic termination of
the contract.

Article 16: Resolutory clause

Each of the parties acknowledges that, in addition to the mechanisms for sanctioning partial non-performance
which they may implement, failure to perform one or other of the obligations listed below may result in automatic
termination of the contract of sale if, after the creditor of the obligation has given the debtor formal notice to
perform, the latter has not been able to remedy the non-performance within one (1) calendar month of receipt of the
said notice, and if:
- The Supplier has failed to comply with any of its obligations relating to the terms of delivery in accordance with the
terms of Article 7 of these conditions;
- The Supplier has failed to comply with its obligation to deliver the goods in accordance with Articles 4 and 10 of
these conditions;
- The Supplier has failed to comply with its warranty obligations as defined in Article 12 of these conditions;
- The Supplier has failed to fulfil its obligations relating to subcontracting, as stipulated in Article 14 of these terms
and conditions;
- The Supplier has failed to comply with its obligation to respect the rules of ethics as specified in Article 15 of these
terms and conditions;
- The Supplier is in breach of its good faith obligation in that it has provided false statements to HI in the various
contractual documents exchanged;
- HI has failed to pay the agreed price;
- HI has failed in its obligation to take delivery of the goods;
- An event of force majeure, as defined in section 17 below, causes a delay of more than three (3) months in the
delivery of the goods.
In this case, the parties acknowledge that if part of the order has been delivered and partial performance has thus
been possible, the termination shall only have effect for the future and HI shall pay the price in proportion to the
items delivered.

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 General Purchasing Conditions

In the event of contracts of successive performance, termination may be executed de jure if one or other of the
above-mentioned cases applies, but without retroactive effect.
In all other cases, the creditor to the obligation shall be legally entitled to terminate the contract. Since termination
then has retroactive effect, if the parties had commenced performance of the contract, they will be required to
return everything acquired from each other.

Article 17: Force majeur

The Parties shall not be held liable for any delay or failure in the performance of their obligations resulting from any
unforeseeable and unavoidable event or circumstance beyond their control, which, in the case in point, would meet
the conditions for classification as force majeure.
Except in the case - specified by article 17 of these general conditions - where the event of force majeure would cause
a delay of more than three months in delivery, any event having the quality of force majeure which would only
temporarily prevent the performance of the obligations of the parties, will only result in the suspension of the obligations
of each party, with the suspension being lifted as soon as circumstances allow.
The parties to the contract acknowledge that they reject the application of Article 1195 of the Civil Code and, for these
purposes, that no event will be deemed to have the quality of unpredictability as defined by the said article.

Article 18: Law applicable to the settlement of disputes

The parties agree that the law applicable to the contract is Pakistan law.
They thus acknowledge that Pakistan law shall apply to any dispute that may have arisen between them as to the
interpretation, formation, performance or non-performance of the contract.

Article 19: Jurisdiction clause

The parties agree that for any dispute arising or to arise between them on the interpretation and/or
application/performance of this contract, they will endeavor to reach an amicable settlement.
In the absence of an amicable settlement, they agree that the Pakistan courts shall have exclusive jurisdiction.

For acceptance by the Supplier

Date: Place:
Name: Function:

Signature preceded by the words “Read and approved” and company stamp:

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 HUMANITY & INCLUSION GOOD BUSINESS PRACTICES

I. Preamble
These Good Business Practices provide the basis of all working relations between HI and its
suppliers.
They are general rules valid unless specific terms are mentioned in the agreement. In the event
of contradictory terms between documents, the terms of the agreement or of the call for
tenders file will take precedence over these Good Business Practices.

II. Supply procedures principles

HI has set up transparent procedures to attribute contracts, of which the key principles are:
 Transparency in the supply procedure
 Proportionality between procedures followed to attribute agreements and the value of
contracts.
 Equal treatment of potential suppliers

Usual criteria to select a supplier are:

- Authorization to buy goods/services in the country
- Financial and economic capacity
- Technical expertise
- Professional capacity

Usual criteria to attribute a contract are:

- The principle of the lowest bid (the cheapest bid satisfying all the conditions required)
- Best value for money

III. Misconduct, ineligibility and exclusion

HI considers each case of misconduct below as a valid reason to exclude a bidder from a call for
tender procedure and end all working relations and agreements with them:

- Fraud: defined as all intentional actions or omissions regarding:

 The use or presentation of false, incorrect or incomplete declarations or documents,
which would lead to fraudulent appropriation or reprehensible retention of HI's or
institutional funding bodies' funds.
 Concealment of information, having the same consequences.
 Use of those funds for reasons other than those for which they had been originally
attributed.
- Active corruption: promising or deliberately granting an advantage to any person so that
they may act or refrain from acting according to their duty in such a way as to damage, or be
capable of damaging the interests of HI or of institutional funding bodies.
Direct corruption: offering HI employees money or gifts in kind to obtain additional contracts
or to continue an agreement
- Collusion: agreement between two rival companies, which would have the probable effect
of increasing prices, cutting production and increasing profits of allied companies to a
greater extent than their natural increase. An attitude of collusion is not automatically based
on the existence of explicit agreements between companies. It may also be tacit.
 - Coercive practices: damaging or threatening to damage, directly or indirectly, persons or
their property in order to influence their involvement in a supply procedure or influence the
performance of an agreement.

- Involvement in a criminal organisation or any other illegal activity established by

judgement by the American Government, European Union, United Nations or any other HI
funding body.

- Immoral human resources practices: use of child labour and non-compliance with
fundamental social rights and work conditions of employees or subcontractors.

HI will exclude from the supply procedure any candidate or bidder in any of the following cases:
 Being in a situation of bankruptcy or liquidation, or in receivership, in an arrangement
situation (with creditors), having suspended business, in proceedings relating to those
subjects or in a similar situation resulting from a procedure resulting from national
regulations or law.
 Being sentenced for an offence within the framework of its professional activity by a
court decision having the force of res judicata.
 Having been found guilty of grave professional misconduct proven by any means
 Not having satisfied obligations relating to the payment of social security contributions
or tax in compliance with legal provisions, either in the country in which the business is
established in HI's country of intervention or in the country in which the Agreement will
be executed.
 Having been found guilty of fraud, corruption, involvement in a criminal organisation or
any other illegal activity that could damage the financial interests of communities.
 Having been declared responsible for grave breach of contract due to non-compliance
with contractual obligations in a previous procurement procedure.
HI will not attribute agreements to candidates or bidders who, in the course of the procedure
will be:
- The subject of conflicting interests
- Guilty of inaccurate declarations by providing information requested by HI to take part in
the agreement procedure or by not providing such information.

IV. Administrative and financial sanctions

Should the supplier, candidate or bidder be involved in corruptive, fraudulent, collusive or
coercive practices, HI would impose:
Administrative sanctions:

A candidate's misconduct will be notified to competent civil or commercial authorities as will be

the immediate end of any professional relations with it.
Financial sanctions:

HI will request the refunding of expenses directly and indirectly related to the conduct of the
new call for tenders or contract attribution procedure. If relevant, the bid guarantee or
performance guarantee will be kept by HI.
V. Information and Access for Funding Bodies
HI will immediately inform institutional funding bodies and will provide them with relevant
information should a supplier, candidate or bidder be involved in corruptive, fraudulent,
collusive or coercive practices.
Furthermore, entrepreneurs accept to guarantee right of access to their financial and
accounting documents so that HI's Institutional Funding Bodies may conduct verifications and
audits.

VI. Documents to be presented by the supplier

Below are the minimum documents that any company or individual entrepreneur wishing to
work with HI needs to produce:
8 Supplier's / company representative's personal national identity paper
9 Status and registration papers of the company
10 Mission order or proxy authorizing the representative to sign the Agreement
11 Copy of tax registration

NB: Additional documents may be requested for a specific contract.

Furthermore, the Supplier must have minimum administrative equipment to be able to issue an
Invoice, Delivery note and own an official stamp.
I, the undersigned …….representative’s name………., representing … company's name ……… certify having read and
understood the rules hereto.
On behalf of the company for which I act, accept the terms of HI Good Business Practices and undertake to
achieve the best performance should the contract be attributed to
I the undersigned, certify that ………….name of the company .............has not been involve and will take all necessary
steps not to be involved in or supply material support or any other resource to individuals or entities that commit,
attempt to commit, recommend, facilitate or participate in fraud, active or indirect corruption, collusion, coercive
practices, involvement in criminal organization or any other illegal activity or that do not respect Human Rights or
basic social rights and minimum work conditions as defined by the International Labor Organization (ILO), in
particular regarding child labor, discrimination, freedom of association, respect of the minimum wage, slave labor
issues and compliance with work conditions and hygiene.
Finally, I hereby certify that ………….name of the company............. is not involved in any current legal action or court
proceedings as plaintiff or defendant, in its own name or on behalf of any other entity, for actions relating to fraud,
corruption or any illegal activity and has never been found guilty of such practices.

Name: Date:
Title: Stamp:

Signature:
 CHILD PROTECTION POLICY FOR SUPPLIERS/STAKHOLDERS

POLICY STATEMENT: 1.3 Prevention

General principles To minimize the risks to children, Handicap International is committed to
At Handicap International we are committed to a set of principles that include in all awareness raising programs, including communication towards
derive from the UN Convention on the Rights of a Child: partners, regular discussion on preventive measures with a specific attention
 All children have equal rights to protection from abuse and to disabled children because of their vulnerable situation.
exploitation 1.4 Responding
 Everyone has a responsibility to support the care and protection of Handicap International is committed to ensuring correct actions are taken to
children support and protect children in accordance with the policy.
 Organisations have a duty of attention to children they and their 1.5 Definitions of child abuse and neglect
representatives work close to. They have to do their best to provide Child abuse is a general term and made up of all forms of physical and
the children receive the care and support they need. or/emotional ill treatment, sexual assault, neglect or negligent treatment or
 Children are actors in their own protection and development, which exploitation, resulting in actual or potential harm to the child’s health,
does not exempt parents and educators from their responsibilities. survival, development or dignity in the context of a relationship of
- Handicap International is committed to the rights of children and will responsibility, trust or power.
not tolerate or accept any form of child abuse. Our Internal  Physical abuse
regulations state that: The actual or likely physical injury to a child, or failure to prevent physical
“The suppliers/stakeholders must show respect and injury or suffering to a child. This may include, burning, hitting, punching,
consideration towards his/her contacts (beneficiaries, shaking, kicking, or beating a child. The worker may not have intended to hurt
partners, colleagues…), with particular attention for the child, however the injury is not an accident. It may have been the result
people in vulnerable situations. In no circumstances should of over-discipline or physical punishment that is inappropriate to the child’s
he/she commit an act or adopt behavior liable to injure one age.
of his/her contacts either physically or psychologically, or  Emotional abuse
cause him/her harm of any sort.  Also known as: verbal abuse, mental abuse, discrimination, forlornness and
The suppliers/stakeholders should respect and promote psychological maltreatment. This refers to the actual or likely adverse effect
respect for the fundamental principles contained in: on the emotional and behavioral development of children caused by
- the international conventions concerning child labour, prostitution persistent or severe emotional ill treatment or rejection. This can include
and people trafficking, and also the traffic of drugs or psychotropic health providers/rehabilitation workers using extreme and or bizarre forms
substances (see appendix). of punishment, such as confinement in a dark room or being tied to a chair
- the child protection policy implemented by the association, including for long periods of time or threatening or terrorizing a child or the
in particular that owning or consulting child pornographic materials is tremendous promises beyond capacity. Less severe behavior, but just as
strictly forbidden. harmful is mocking, using insulting names for a child, or blaming.
If he/she observes any breach in these principles or  Sexual abuse
behavior liable to contribute towards any of the crimes  This refers to inappropriate sexual behavior between a child and an adult who
cited above, appropriate sanctions may be applied. is in a relationship of responsibility, trust or power. It includes fondling a
As supplier/stakeholder he/she is also required to guard child’s genitals, making the child fondle the adult’s genitals, intercourse, rape,
against any abuse of authority. In no circumstances should sodomy, exhibitionism, sexual exploitation, child prostitution and
he/she profit from his/her situation in order to divert pornography.
assistance from its final destination or obtain favors of any  Child labor
nature (notably sexual).”  Child labor includes full-time work done by children under 15 years of age
Awareness that prevents them from going to school (getting an education), or that is
Handicap International is committed to raising awareness amongst its dangerous to their health (International Labor Organization, Convention
staff and its partners including stakeholders/suppliers so they 138). Child labor is permitted from 15 years old, except for activities that
understand the principles, policy, reporting, and monitoring framework could in any way undermine health or morals of the child. Handicap
of the Child Protection Policy. International will be very cautious concerning this limit of age, and, in full
if there is a breach of policy, supplier/stakeholders are aware of the respect of national legislations, will nevertheless urge its staff to contract
disciplinary procedures that would follow. with people over 18.
 owning or consulting child pornographic materials is strictly  Child work
forbidden.  Children’s participation in economic activity - that does not negatively affect
 gender sensitiveness is essential when addressing child protection their health and development or interfere with education. No economic
issue. activity is allowed for children under 12 (International Labour Organization,
 all disabled children have equal rights to be treated with dignity, Convention 138).
respect, sensitivity and fairness. 2.1 Procedure in case of breach of the policy
 community programs strongly emphasize the commitment we make
i) Handicap International reserves the right to immediately terminate the
to ensuring all disabled children attend school, that they are not
forced into child labour and that they have an opportunity to be contract, without notice and without penalties if the organization discovers
heard. that this rule is not respected by the Supplier.
1.3 Prevention ii) Handicap International will be particularly monitoring this issue
To minimize the risks to children, Handicap International is
2.2 Confidentiality
committed to include in all awareness raising programs, including
communication towards partners, regular discussion on preventive In all matters relating to this policy, it is essential to respect the duty of
measures with a specific attention to disabled children because of confidentiality. This means no information offered by children and / or other
their vulnerable situation. individuals about any form of child abuse should be made public.
Declaration:
I the undersigned, certify that I have read the policy carefully and I respect and assure to be bound to the policy. I commit not to contract any employee, agent
or subcontractor who is under 18 years old or without NIC card. I also understand the laws defined by the International Labour Organization (ILO), in particular
regarding child labour, discrimination, freedom of association, respect of the minimum wage, slave labour issues and compliance with work conditions and
hygiene.
Name of supplier/stakeholder: ___________________________ Organization Name: ____________________________

Sign & Stamp: _________________________ Date: ____________________________

 PROTECTION OF BENEFICIARIES FROM SEXUAL EXPLOITATION AND ABUSE

1. Objectives of the Protection from Sexual Exploitation and Abuse Another aid organisation, he or she must report such concerns through
(PSEA) policy the line-management channels, or should this be the case, to the
programme’s PSEA focal point.
Through this policy, Handicap International expresses its determination In concrete terms, this means reporting concerns or suspicions,
to combat the sexual exploitation and abuse of aid beneficiaries by including rumours, in good faith, without attempting to investigate the
humanitarian workers. It is therefore implementing a series of matter personally in order to obtain proof or write a report. Reprisals
measures intended to reduce risks on its programmes, whatever the against any staff member having reported sexual exploitation or abuse
context. is prohibited.
Handicap International also encourages its staff to think about their
actions and the potential consequences of these actions. 6. Handicap International undertakes to ensure that any allegations
2. Definitions remain confidential and that an impartial internal investigation is
Handicap International has based the following definitions on those of carried out that will not, however, replace investigations which may be
the United Nations: conducted by the competent local authorities. If reported information
Sexual abuse: concerns a partner of Handicap International or any other aid

 Actual or threatened physical intrusion

organisation, the Field Programme Director/ Head of Mission will be
required to take the appropriate measures.
 of a sexual nature
7. All Handicap International staff members, and managers in particular,
 whether by force or under unequal or coercive conditions whatever their level, are expected to create and maintain an
environment that prevents sexual exploitation and sexual abuse.
This means that the use of actual force is not necessary to constitute
sexual abuse. Sexual abuse can also occur in situations of inequality or Preventing a culture of complacency and impunity demands
under coercive conditions. continuous effort. Managers, amongst others, must be familiar with
and enforce this policy. They must be proactive in overseeing their
Sexual exploitation: teams.
 Any actual or attempted abuse of a position of vulnerability, Staff responsible for project implementation, follow-up and evaluation
differential power, or trust and for fund-raising must be particularly mindful of risks of sexual
 for sexual purposes, exploitation or sexual abuse, in accordance with activities and context.
Risk reduction strategy must be a matter of constant concern.
 including, but not limited to, profiting monetarily, socially or
politically from the sexual exploitation of another. 8. Handicap International undertakes to provide assistance to any
individual who files a complaint with the organisation, and to ensure
This means that any individual acting as an intermediary in the specific assistance and support for the victims of sexual exploitation or
organisation of abuse is equally guilty of exploitation. sexual abuse perpetrated by one of its staff members.
3. Principles
Victims will be informed that perpetrators of acts of sexual exploitation
1. Sexual exploitation and sexual abuse perpetrated against or sexual abuse hold full responsibility for their actions, irrespective of
beneficiaries constitute serious misconduct and are the nature of the assistance provided by Handicap International.
therefore grounds for disciplinary action.

2. Sexual activity with persons under the age of 18 is 4. Disciplinary measures

prohibited regardless of the age of majority or age of
consent locally1. Mistaken belief in the age of a person is not Any staff member failing to comply with the principles or failing to
considered a defence. meet the requirements set forth in this protection policy may face
disciplinary action.
3. Exchange of money, employment, goods, services or any
type of assistance for sexual favours is prohibited.
5. Scope of the policy
4. Sexual relationships between Handicap International staff
and aid beneficiaries are strongly discouraged, as they are The principles set forth in this policy apply:
based on an inherently unequal power relationship and - To all Handicap International staff, whether expatriates or national,
undermine the credibility and integrity of Handicap throughout the federal network.
International's work. - At all times, i.e. during and outside of office hours and during periods
of leave.
5. Where a Handicap International staff member develops - To all people or entities who have signed a contract with Handicap
concerns or suspicions with regard to possible sexual International: consultants, day labourers, suppliers, partner
exploitation or sexual abuse by a fellow worker, whether organisations, etc.
the individual works for Handicap International or for
Declaration:
I the undersigned, certify that I have read the policy carefully and I respect and assure to be bound to the policy. I commit not to contract any employee, agent
or subcontractor who is under 18 years old or without NIC card. I also understand the laws defined by the International Labour Organization (ILO), in particular
regarding child labour, discrimination, freedom of association, respect of the minimum wage, slave labour issues and compliance with work conditions and
hygiene.
Name of supplier/stakeholder: ___________________________ Organization Name: ____________________________

Sign & Stamp: _________________________ Date: ____________________________

Institutional directives

Code of conduct: Integrity,

and
Safeguarding

Federal Executive Division

1
 Institutional Directives

Code of conduct: Integrity,

Prevention of abuseand
safeguarding

1. INTRODUCTION 3
1.1 Why the need for a code of conduct?
1.2 What are the foundations of this code of conduct?
1.3 What purpose will the code serve?
1.4 To whom does it apply?
1.5 What is the role and importance of this code of conduct?

2. CODE OF CONDUCT 6
2.1 Relations
2.2 Elimination of sexual exploitation and abuse situations
2.3 Work environment
2.4 Fraud & Corruption
2.5 Communication
2.6 Reporting

2
1.
Introduction

1.1

Why the need for a code of conduct?

Humanity & Inclusion (HI) is an international aid and development

organisation engaged in promoting the rights of people with disabilities
and vulnerable people, and Human Rights in general. The respect and
dignity of the concerned people and the beneficiaries of the actions and
communities are at the heart of the commitment of the staff and other
collaborators (volunteers or partners, for example) of HI, in all contexts
of intervention.

HI’s reputation depends largely on the quality and accountability of its

staff, and so on their conduct. Even during difficult missions, HI aims to
promote engagement of the highest quality. Non-respect of the
organisation’s values undermines the reputation of the whole
organisation. It is important to bear in mind that each member of our
organisation represents HI both during and outside working hours.

HI’s staff regularly find themselves in positions of trust or power with

regard to the beneficiaries and communities concerned. They may not
feel this to be the case, but it is the unavoidable result of the economic
and symbolic differences between an NGO’s personnel and the people
benefiting from its actions. Demonstrating awareness of this and respect
for HI’s values means behaving in an appropriate fashion and feeling
responsible for and complying with its codes and ethical principles.

3
1.2

What are the fundamental pillars of this Code of Conduct?

This code of conduct is a key element in the implementation of

institutional policies that lay down the fundamental principles for
the protection of the resources entrusted to HI, but above all for the
protection of our beneficiaries - especially those most vulnerable to
the abuse of power, with particular attention to discrimination,
gender-based behavior, sexual exploitation and abuse - and of our
own staff. These policies are notably:

▪ Protection of beneficiaries from sexual exploitation and abuse

▪ Child protection
▪ Fight against fraud and corruption.

The principles on which these policies are based are as follows:

• Respect for fundamental human rights, including the rights of the
child, disability rights and international humanitarian law,
• Zero tolerance on the part of the organisation regarding
violations of these rights by its staff and associates, and at all
times,
• Risk management, including establishing a protective
environment,
• The duty of assistance to victims, abused by HI staff or other
community actors
• The duty to report all incidents, doubts or suspicions of abuse,
even in the absence of proof.

This code of conduct aims to protect all the beneficiaries of HI’s actions,
direct and indirect, as well as people in the communities in contact with
these actions, especially children, women, people with disabilities or
elderly people and anyone in a situation of vulnerability.

4
1.3

What purpose will the code serve ?

The code sets forth the expected behaviors and practices constituting
the organisation’s minimum standards as well as actions to be
avoided to ensure relations with the beneficiaries or between members
of HI’s staff are respectful of the ethics developed by the organisation
via its policies. Its purpose is therefore to help staff:
➢ understand better their obligations and responsibilities with
regard to the above-mentioned policies put in place by HI,
➢ take the appropriate decisions and adopt appropriate behavior in
both their professional and private lives.

Managers have a particular responsibility to ensure that their teams

comply with this code by ensuring that the work environment is
conducive to the application and ownership of the principles mentioned.
Failure to comply with this code of conduct may lead to managerial
sanctions including dismissal, as well as notifications in HR files.

1.4

To whom does it apply?

The Code, which must be signed personally by all the people concerned,
applies world-wide to anyone working on behalf of HI or as part of a
project or an action conducted with HI, whether recruited internationally
or nationally or working on an ad hoc basis on HI’s projects and actions.
It thus applies to all people having signed a permanent or fixed-term
employment contract with HI, as well as any family members
accompanying international staff, as well as to consultants, interns,
5
voluntary workers or international volunteers, service providers and
partner organisations, by dint of their collaboration with HI.
It applies to all these people in all situations, professional or otherwise,
during working hours and outside working hours. For simplicity’s sake,
these people will be referred to as “HI staff and collaborators” in this
document.

The code of conduct must be signed individually by all persons involved.

1.5

What is the role and importance of this code of conduct?

This code of conduct translates the above-mentioned institutional

policies and the institutional protection guidelines into concrete action.
It is an addition to the existing documents for defining HI’s working
environment, which are:
▪ Humanity & Inclusion’s Charter and byelaws,
▪ the Rules of Procedure, which notably define psychological and
sexual harassment,
▪ the general and specific terms and conditions of engagement,
which define the contractual conditions for international staff and
national staff,
▪ the employment contract, service contract or any other
formalisation of a professional relationship, which is specific to
each person or situation and makes reference to all the rules to
be applied.

This code of conduct does not replace these documents.

2.

Code of conduct
6
In every context, regardless of the emergency of the situation, as a member of
HI staff or as a collaborator, I commit to respect the following:

2.1

Relations

I will always make sure that beneficiaries (including children), staff and
partners are treated with respect, dignity and equality regardless of their
age, sex, physical condition, impairment, language, religion, opinion,
nationality, ethnic or social origin, status, class, caste, sexual orientation,
or any other personal characteristics.

I will always promote non-violent and positive behavior when

supervising or interacting with beneficiaries.

I do not participate in or encourage corrupt or fraudulent actions that

harm the beneficiaries and/or the organization. I do not demand or accept
any commission, consideration, or gift for my decisions or actions.

I do not touch beneficiaries in any way that is inappropriate for the

cultural environment in which they live.

I will never use language or make suggestions to provoke, harass or

degrade the person or knowingly show disrespect for traditional or
cultural practices.

I will never subject to beneficiaries any kind of sexist, humiliating,

degrading or abusive behavior, whether physical, verbal or
psychological or of other nature.

I will always inform beneficiaries (including children) and communities

7
of their right to report any worrying situations, especially related to
intimacy issues and how they can raise a concern.

I will always try to take into account the capacity of the beneficiary to
participate, to respect his/her opinion, choices and autonomy, not doing
things of a personal nature that the beneficiary can not do for
themselves (e.g. toileting/ changing clothes, etc.).

I will always pay specific attention to people facing obstacles or

difficulties in communicating or fully expressing themselves (related to
impairment, mobility, gender or any other reason) by providing
appropriate, adequate and safe communication spaces and tools.

When I am in contact with a beneficiary (with a special attention to

childrenand women as well as men with disabilities), I will always make
sure that thebeneficiary is visible to another adult.

2.2

Elimination of sexual abuses and exploitation

I will never engage in any form of sexual relations with anyone under 18
years old, regardless of the age set by the sexual majority, the law or
local customs. Mistaking a child’s age is not a defense.

I do not engage in any type of sexual relationship or favor in exchange

for money, a gift of any kind, work, or humanitarian aid, even if it is
offered or expected by the persons involved. This rule applies in all
circumstances, including if these individuals are considered as sex
workers, or are referred by a third party as such.

I do not, under any circumstances, directly or indirectly, use an adult or

child to provide sexual services to another person, nor do I support,
enable or participate in any form of prostitution or sexual exploitation.
8
Under no circumstances will I sexually exploit any HI beneficiary or staff
member, nor will I make a child work (including for domestic duties) in
exchange for assistance/help or any type of benefit.

2.3

Working environment

I will always treat beneficiaries, especially children and people with

disabilities, in an equitable and fair way, never discriminating against
them for example by favoritism or by excluding others.

I will always show respect to all categories of employees, partner’s staff,

community volunteers or beneficiaries.

I will never engage in or tolerate any form of harassment, discrimination,

physical or verbal abuse, intimidation or favoritism in the workplace,
including sexist and racist behaviours or sexual and psychological
harassment and abuse of power, respecting the rules that apply to me
(especially Internal Rules) on these issues.

I will always behave in a professional way with colleagues, avoiding

spreading rumours and false allegations and refraining from any
comment based on gender, sexual orientation, or any other personal
characteristics – which may be considered as harassment.

I will always assess the risk of harm of any sort related to project’s
implementation including financial and material. I will organize the
workplace, plan activities and being attentive to any conflict of interest’s
issues to minimize it, taking into account the impairment, health
condition, age and development of the child or any other condition or
vulnerability of staff (interns, cleaning staff, etc) and beneficiaries.

9
I will always plan activities ensuring that information concerning
beneficiaries, children, families and communities remains confidential
and in respect of the data protection laws applicable to the concerned
environment.

I will never invite a beneficiary (especially a child) to my home, offer to

transport him/her, or maintain personal contact (phone, media, and
social networks) with him/her without a professional reason, and
without clear authorization from my manager.

2.4

Fight against fraud and corruption

I protect the material and financial resources of the organization against

any form of waste, loss, theft or misappropriation.

I ensure that the aid destined for the beneficiaries of our actions reaches
them, in the quantities and at the level of quality expected.

I do not demand or accept commissions, no any compensation or gifts

for my decisions or actions.

I will not accept facilitation payments (baksheesh), which are designed

to speed up the process by avoiding the rules.

I inform my organization of all invitations and gifts received or offered. I

refuse all invitations and gifts that result in a real or perceived loss of
objectivity and impartiality.

I make objective choices in the best interests of the organization, without

seeking advantages, favors or profits for family members, friends or
myself.

10
I inform my organization of potential conflict of interest situations and,
when inappropriate, I do not participate in decisions that could be
considered non-objective or self-serving.

I perform my duties without abusing the authority or responsibilities

entrusted to me in order to obtain personal gain.

2.5

Communication

For any photo taken or video made, I ask for prior authorization from the
person concerned or his or her legal representative (minor or under
guardianship). Prior authorization cannot be obtained under pressure or
in exchange for an individual service.

When a photo is taken or a video is made, with the appropriate prior

authorization, I always ensure that the person is not depicted in a
degrading or sexually suggestive way.

I will always use respectful words and the people’s names when
speaking to them and to other persons or communicating on them.

I will never watch, publish, produce, or share pornography showing

children, and / or show such material to children.

I will always ensure that all audio, written or visual communication

respects the dignity and human rights of the person featured (including
anonymity when necessary, mandatory for children in high vulnerability
situation), and does not expose her or him to any risk of retaliation or
abuse of any nature.

I will always ensure when taking and publishing photos that

beneficiaries or children are not naked or dressed in a manner which is
11
not adapted to the situation in which they are represented.

I will never show the faces of beneficiaries or children who are exploited
sexually, victim of trafficking or abuse, in conflict with the law, linked to
armed groups or who can easily be located even if their identity has been
modified.

2.6

Reporting

I will always raise any concern and query concerning the present Code
of conduct, the PSEA and the Child Protection Policy, the Fraud &
Corruption policy, with my manager / supervisor, or if not possible, with
another from my hierarchy or with a designated focal person (according
to the rules to internal reporting rules).

I will immediately report any suspicions or allegations of behaviour

going against the principles of the present Code of conduct, the PSEA
and the Child Protection Policy or fraud & corruption policy in the
EthicsPoint system with, if necessary, the support of my direct manager
- even if the information or allegations are unspecific, and without having
first investigated them myself.

I never deliberately make false accusations or spread false rumors about

a colleague, or any other person, in regard to non-compliance with this
code of conduct.

I agree to cooperate, confidentially and impartially, with internal

investigations as determined by my organization.

12
For people who are part of HI (members and personnel), a
professional whistle-blowing mechanism is available on
Hinside, the organisation’s platform for internal
communication and collaboration: https://hinside.hi.org/
intranet/jcms/prod_2149085/en/professional-whistle-
blowing-mechanism

For people from outside HI (beneficiaries, partners,

suppliers, others),a complaint system is available on
the organisation’s website:
https://hi.org/en/institutional-and-professional-
information#ancre10Or write to the following
address:
Humanity
&
Inclusion
Complain
ts
138 avenue des
Frères LumièreCS
88379
69371 Lyon
Cedex 08
France

Contact:
Risks and Audit Division

13
On 24 January 2018,
Handicap International’s global movement became
Humanity & Inclusion.
The Federation, which runs projects in around sixty
countries, is now working under the operating names of
“Humanity & Inclusion”, “Handicap International” or
“Atlas Logistique”. Any document with the letterhead
“Humanity & Inclusion” applies de facto to Atlas
Logistique and Handicap International teams.

Photo credit: 2017 / bpcraddock / Pixabay /Creative Commons

14
Code of conduct:
Integrity, Prevention of
abuseand
safeguarding

As an aid and development organisation promoting respect for the

dignity and fundamental rights of people with disabilities and vulnerable
populations, HI is committed to ensuring the protection not just of its
beneficiaries, but also of all those in contact with its actions.
Each member of HI represents the organisation and is responsible for
safeguarding its image. Any lack of respect for its values damages HI’s
reputation and can undermine the legitimacy of its actions.
This Code of conduct outlines the behaviours and practices expected of you
with regard to the protection of beneficiaries from sexual exploitation and
abuse, as well as the actions to be avoided in order to guarantee that the
relations created within our teams, with our beneficiaries and with all those
in contact with our organisation are respectful of HI’s ethics and, more
generally, of the values it defends.

Humanity & Inclusion

138 avenue des Frères Lumière
CS 88379
69371 Lyon Cedex 08

[email protected]
69371 Lyon Cedex 08

15
 Appendix 5:
HI Good Business Regulation

These Good Business Regulations are the ground for a professional working relationship
between HI and the Service Providers.
They are general regulations valid unless others particular conditions are mentioned in the
contract. In case of conflicting terms within documents, the conditions of the contract or tender
dossier will prevail on these Good Business Regulations.

I - Principles of the procurement procedures

HI has transparent procedures to award markets. Essential principles are
– Transparency in the procurement process
– Proportionality between the procedures followed for awarding contracts and the value of
the markets
– Equal treatment of potential Service Providers
Usual criteria to select a Service Provider are:
- Authorisation to perform the market
- Financial capacities
- Economic capacities
- Technical expertise
- Professional capacities
Usual criteria to award markets are:
- Automatic award (the cheapest offer complying with all requirements)
- Best value for money (price/quality ratio)

II - Misbehaviour, ineligibility and exclusion

HI considers the following misbehaviour as a valid ground for a systematic exclusion of an
awarding market procedure and for the termination of all working relationship and contracts:
- Fraud defined as any intentional act or omission relating to:
• The use or presentation of false, incorrect or incomplete statements or documents,
which has as its effect the misappropriation or wrongful retention of HI or institutional
donor’s funds
• Non-disclosure of information, with the same effect
• The misapplication of such funds for purposes other than those for which they were
originally granted
- Active corruption: to deliberately promise or give an advantage to an official for him/her to
act or refrain from acting in accordance with his duty in a way which damages or is likely to
damage HI or institutional donor’s financial interests
- Collusion: the co-ordination of firm’s competitive behaviour, with the likely result that prices
rise, output is restricted and the profits of the colluding companies are higher than they would
otherwise be. Collusive behaviour does not always rely on the existence of explicit agreements
between firms, but can also be tacit.
- Coercive practice: harming or threatening to harm, directly or indirectly, persons, or their
property to influence their participation in a procurement process, or affect the execution of a
contract.
- Bribery: to offer HI employees monetary or in kind gifts in order to gain additional markets or
to continue a contract

1/8
- Involvement in a criminal organisation or any other illegal activity established by a
judgement, by the US Government, the European Union, the United Nations or any donor
funding HI.
- Immoral Human Resources practices: exploitation of child labour and the non-respect of basic
social rights and working conditions of employees or sub-contractors

HI will exclude from a procurement procedure any candidate or tenderer falling into one of the
following cases:
- To be bankrupt or to be wound up, to have affairs administered by the courts, to have enter
into an arrangement with creditors, to have suspended business activities, to be the subject of
proceedings concerning those matters, or are in any analogous situation arising from a similar
procedure provided for in national legislation or regulations
- To have been convicted of an offence concerning professional conduct by a judgement that
has the force of res judicata
- To have been guilty of grave professional misconduct proven by any means that HI can justify
- To have not fulfilled obligations relating to the payment of social security contributions or the
payment of taxes in accordance with the legal provisions of the country in which they are
established or with those of the country where HI mission is operating or those of the country
where the contract is to be performed
- They have been the subject of a judgement for fraud, corruption, involvement in a criminal
organisation or any other illegal activity detrimental to the Communities' financial interests
- To have been declared to be in serious breach of contract for failure to comply with their
contractual obligations in another previous procurement procedure

HI will not award contracts to candidates or tenderers who, during the procurement procedure:
- Are subject to a conflict of interest
- Are guilty of misrepresentation in supplying the information required HI as a condition
of participation in the contract procedure or fail to supply this information

III - Administrative and financial sanctions

In the event a Service Provider, candidate or tenderer is engaged in corrupt, fraudulent, collusive
or coercive practices HI will impose:
- Administrative sanctions:
Administrative sanctions are the official notification of the misconduct to the relevant civil or
commercial authorities and the immediate termination of all existing working relationships.
- Financial sanctions:
HI will request the reimbursement of the cost linked directly and directly to the conduct of a new
tendering process or market award. If any, the tender or performance guarantee will be kept by
HI.

IV - Information of the Donors

HI will inform immediately the Institutional Donors and will provide all the relevant information in
the event a Service Provider, candidate or tenderer is engaged in corrupt, fraudulent, collusive or
coercive practices.

V - Provision for institutional donors

The contractors agree to guarantee a right of access to their financial and accounting documents
to the representatives of HI’s institutional donors for the purposes of checks and audits.

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VI - Documents to be a Service Provider
Hereafter is the minimal documentation a contractor working with HI will have to provide:
- Personnel national ID document of the Service Provider/company representative
- Status and registration of the company
- Mission order or power of attorney authorising the representative to contact
Important note: Additional documentation may be required for a particular market.

In addition, the contractor must have the capacity to issue invoices, receipts and waybills (or
delivery notes), to provide a tax clearance certificate and certify documents with an official
stamp.

Appendix E:
HI Child Protection Policy

Disabled children have the same rights as all children. However, they can be all the most
vulnerable because they are often invisible, isolated, discriminated against and abused in a variety
of ways. They lack power, respect and life prospects all over the world.
Handicap International promotes the rights of disabled children to develop their potential, get an
education, have a say, and take part in mainstream society. Handicap International believes that
disabled children have the rights to protection, to live and prosper in their own family and
community.
Everyone working with children has a basic duty of attention toward them. Handicap
International, its staff and its partners must recognize the risks to children and the responsibilities
to keep them safe. If children are to be protected from abuse and exploitation Handicap
International, its staff and its partners must conduct themselves with the highest levels of
professionalism and integrity at all times.
The present policy aims at protecting children from intentional and non-intentional harm or
abuse. It applies both to Handicap international, as an organization, and individuals (local and
expatriates) associated with Handicap International towards children in their care. Handicap
International will also pay a specific attention to the conduct of its partners regarding child
dignity.
Broader child protection concerns outside the organization should be dealt with programme and
project activities.
I. POLICY STATEMENT: PREVENTING ABUSES
1.1 General principles
At Handicap International we are committed to a set of principles that derive from the UN
Convention on the Rights of a Child:
• All children have equal rights to protection from abuse and exploitation
• Everyone has a responsibility to support the care and protection of children
• Organisations have a duty of attention to children and their representatives’ work
close to. They have to do their best to provide the children receive the care and
support they need.
• Children are actors in their own protection and development, which does not exempt
parents and educators from their responsibilities.
Handicap International is committed to the rights of children and will not tolerate or
accept any form of child abuse. Our Internal regulations state that:

3/8
 “The employee must show respect and consideration towards his/her contacts
(beneficiaries, partners, colleagues…), with particular attention for people in vulnerable
situations. In no circumstances should he/she commit an act or adopt behaviour liable to
injure one of his/her contacts either physically or psychologically, or cause him/her harm
of any sort.
The employee should respect and promote respect for the fundamental principles
contained in:
- The international conventions concerning child labour, prostitution and
people trafficking, and also the traffic of drugs or psychotropic
substances.The child protection policy implemented by the association,
including in particular that owning or consulting child pornographic
materials is strictly forbidden.
If he/she observes any breach in these principles or behaviour liable to contribute
towards any of the crimes cited above, he/she should inform the Field Program Director
immediately so that appropriate sanctions may be applied.
As an employee of a humanitarian organisation, he/she is also required to guard against
any abuse of authority. In no circumstances should he/she profit from his/her situation in
order to divert assistance from its final destination or obtain favours of any nature
(notably sexual).”
Handicap International encourages the creation of dedicated spaces to allow children in
the program to raise issues regarding their safety.

1.2 Awareness
Handicap International is committed to raising awareness amongst its staff and its partners
so they understand the principles, policy, reporting, and monitoring framework of the
Child Protection Policy.
Staffs at Handicap International are informed about the Child Protection Policy and if there
is a breach of policy, staff are aware of the disciplinary procedures that would follow.
Staffs at Handicap International are informed that owning or consulting child pornographic
materials is strictly forbidden.
Staffs at Handicap International are informed about the UN Convention of the Rights of
the Child and this forms the basis for our staff policy regarding the issue of child
protection.
Staffs at Handicap International are informed that gender sensitiveness is essential when
addressing child protection issue.
Staffs at Handicap International are aware that all disabled children have equal rights to be
treated with dignity, respect, sensitivity and fairness. Staffs are also aware that community
programs strongly emphasize the commitment we make to ensuring all disabled children
attend school, that they are not forced into child labour and that they have an opportunity
to be heard.
Handicap International ensures that its implementing partners are informed about that
policy.
1.3 Prevention
To minimize the risks to children, Handicap International is committed to include in all
awareness raising programs, including communication towards partners, regular
discussion on preventive measures with a specific attention to disabled children because
of their vulnerable situation.
1.4 Reporting

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 Handicap International is committed to ensuring staff are clear about the reporting
procedures included in this document.
1.5 Responding
Handicap International is committed to ensuring correct actions are taken to support and
protect children in accordance with this policy.
1.6 Definitions of child abuse and neglect
Child abuse is a general term and made up of all forms of physical and or/emotional ill
treatment, sexual assault, neglect or negligent treatment or exploitation, resulting in
actual or potential harm to the child’s health, survival, development or dignity in the
context of a relationship of responsibility, trust or power.
• Physical abuse
The actual or likely physical injury to a child, or failure to prevent physical injury or
suffering to a child. This may include, burning, hitting, punching, shaking, kicking, or
beating a child. The worker may not have intended to hurt the child; however the injury is
not an accident. It may have been the result of over-discipline or physical punishment that
is inappropriate to the child’s age.
• Emotional abuse
Also known as: verbal abuse, mental abuse, discrimination, forlornness and psychological
maltreatment. This refers to the actual or likely adverse effect on the emotional and
behavioural development of children caused by persistent or severe emotional ill
treatment or rejection. This can include health providers/rehabilitation workers using
extreme and or bizarre forms of punishment, such as confinement in a dark room or being
tied to a chair for long periods of time or threatening or terrorizing a child or the
tremendous promises beyond capacity. Less severe behaviour, but just as harmful is
mocking, using insulting names for a child, or blaming.
• Sexual abuse
This refers to inappropriate sexual behaviour between a child and an adult who is in a
relationship of responsibility, trust or power. It includes fondling a child’s genitals, making
the child fondle the adult’s genitals, intercourse, rape, sodomy, exhibitionism, sexual
exploitation, child prostitution and pornography.
• Child labour
Child labour includes full-time work done by children under 15 years of age that prevents
them from going to school (getting an education), or that is dangerous to their health
(International Labour Organization, Convention 138). Child labour is permitted from 15
years old, except for activities that could in any way undermine health or morals of the
child. Handicap International will be very cautious concerning this limit of age, and, in full
respect of national legislations, will nevertheless urge its staff to contract with people over
18.
• Child work
Children’s participation in economic activity - that does not negatively affect their health
and development or interfere with education. No economic activity is allowed for children
under 12 (International Labour Organization, Convention 138).

II. PROVISIONS
2.1 Recruitment, selection, induction
All new staff employed on a permanent/part time/temporary contract at Handicap
International will be made aware of this policy during the briefing/training period, and/or
at any other appropriate occasion. Internal regulations of Handicap international contain a
statement concerning their respect of children’s rights to protection from abuse.

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 The job contract will contain a clause requiring the staff member to agree not to get
involved in any form of child abuse and to protect children from abuse throughout the
course of their work.
2.2 Procedure in case of breach of the policy
When concerns or an allegation of abuse or neglect are raised by a child, parents, family
members, caregivers, staff, volunteers or consultants, the following procedure is required.
• The staff member who initially was made aware of the abuse must report this directly
to its immediate manager/team leader/supervisor. This immediate supervisor will then
discuss with the Field Program Director who will inform the headquarters, in order the
issue is addressed. If the staff member’s immediate manager is undertaking the abuse,
the staff member must take their concerns to the Field Program Director (or the Desk
Officer if the FPD is undertaking the abuse).
• The accused can be immediately suspended to allow time for an investigation and
decisions on appropriate actions. Following investigations, a written statement
concerning the decisions and a justification will be issued by the Field Program Director
to the accused. According to the gravity of the offence, the staff member will be
punished by: warning followed by professional counselling; or strong written statement
followed by a period of close supervision; or dismissal. In the most serious cases, the
Executive Director’s Office will set up a sanction commission devoted to determine the
appropriate sanction and possibly explore the relevant possibility of seeking the advice
of any relevant person or specialized organization.
• Handicap International will not, in any way, obstruct legislation, and will join forces to
ensure a fair process in case one of its staffs, whether local or international, would be
accused.
• Any intentional false accusation made against a staff member to damage her/his
reputation will be subject to investigation and disciplinary action.

2.3 Confidentiality
In all matters relating to this policy, it is essential to respect the duty of confidentiality.
This means no information offered by children and / or other individuals about any form of
child abuse should be made public without their prior approval and only through the Field
Program Director.
At all times we will ensure that the children (and their families) are kept fully informed of
the process involved for managing this incident and the outcomes.
Concerns, allegations or disclosure will be recorded in writing. Recordings will be as precise
as possible, giving an exact account of what happened, how it happened etc. This will also
include the sequence of events and all subsequent actions taken. All records will be
securely locked and access will be restricted by the Field Program director, under the
control of the Headquarters (Desk officer and Human Resources Direction). At all times the
transfer of information (either verbally or electronically) must be done in such a way that
confidentiality is maintained.
In case the allegation regards a staff from another organization, Handicap International
Field Program Director will decide how to raise the issue with the organization involved
before considering reporting to a third part.
2.4 Relations with partners
Handicap International will not contract in any partnership with organizations which staff
or members may commit abuses on children, as described in § 1.6. Established information
revealing such practices would lead Handicap International to interrupt the partnership
unless a radical change in behaviour is ensured and recorded.

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III. MONITORING
Policy and practices are monitored permanently.
The Field Program Director is responsible for information about policy and practice, and for
monitoring all matters relating to abuse within the organization and reporting to the
Headquarters (Desk officer and Human Resources Direction).

Appendix F:
HI Protection of Beneficiaries from Sexual Exploitation & Abuse

1. Objectives of the Protection from Sexual Exploitation and Abuse (PSEA) policy

Through this policy, Handicap International expresses its determination to combat the sexual
exploitation and abuse of aid beneficiaries by humanitarian workers. It is therefore implementing
a series of measures intended to reduce risks on its programmes, whatever the context.

Handicap International also encourages its staff to think about their actions and the potential
consequences of these actions.

2. Definitions
Handicap International has based the following definitions on those of the United Nations:

Sexual abuse:
• Actual or threatened physical intrusion
• of a sexual nature
• whether by force or under unequal or coercive conditions

This means that the use of actual force is not necessary to constitute sexual abuse. Sexual abuse
can also occur in situations of inequality or under coercive conditions.

Sexual exploitation:
• Any actual or attempted abuse of a position of vulnerability, differential power, or trust
• for sexual purposes,
• Including, but not limited to, profiting monetarily, socially or politically from the sexual
exploitation of another.

This means that any individual acting as an intermediary in the organisation of abuse is equally
guilty of exploitation.

3. Principles
1. Sexual exploitation and sexual abuse perpetrated against beneficiaries constitute serious
misconduct and are therefore grounds for disciplinary action.
2. Sexual activity with persons under the age of 18 is prohibited regardless of the age of
majority or age of consent locally1. Mistaken belief in the age of a person is not considered
a defence.

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 3. Exchange of money, employment, goods, services or any type of assistance for sexual
favours is prohibited.
4. Sexual relationships between Handicap International staff and aid beneficiaries are
strongly discouraged, as they are based on an inherently unequal power relationship and
undermine the credibility and integrity of Handicap International's work.
5. Where a Handicap International staff member develops concerns or suspicions with regard
to possible sexual exploitation or sexual abuse by a fellow worker, whether the individual
works for Handicap International or for another aid organisation, he or she must report
such concerns through the line-management channels, or should this be the case, to the
programme’s PSEA focal point.
In concrete terms, this means reporting concerns or suspicions, including rumours, in good
faith, without attempting to investigate the matter personally in order to obtain proof or
write a report. Reprisals against any staff member having reported sexual exploitation or
abuse is prohibited.
6. Handicap International undertakes to ensure that any allegations remain confidential and
that an impartial internal investigation is carried out that will not, however, replace
investigations which may be conducted by the competent local authorities. If reported
information concerns a partner of Handicap International or any other aid organisation,
the Field Programme Director/ Head of Mission will be required to take the appropriate
measures.
7. All Handicap International staff members, and managers in particular, whatever their level,
are expected to create and maintain an environment that prevents sexual exploitation and
sexual abuse.
Preventing a culture of complacency and impunity demands continuous effort. Managers,
amongst others, must be familiar with and enforce this policy. They must be proactive in
overseeing their teams.
Staff responsible for project implementation, follow-up and evaluation and for fund-raising
must be particularly mindful of risks of sexual exploitation or sexual abuse, in accordance
with activities and context. Risk reduction strategy must be a matter of constant concern.
8. Handicap International undertakes to provide assistance to any individual who files a
complaint with the organisation, and to ensure specific assistance and support for the
victims of sexual exploitation or sexual abuse perpetrated by one of its staff members.
Victims will be informed that perpetrators of acts of sexual exploitation or sexual abuse
hold full responsibility for their actions, irrespective of the nature of the assistance
provided by Handicap International.

4. Disciplinary measures
Any staff member failing to comply with the principles or failing to meet the requirements
set forth in this protection policy may face disciplinary action.

5. Scope of the policy

The principles set forth in this policy apply:
- To all Handicap International staff, whether expatriates or national, throughout the federal
network.
- At all times, i.e. during and outside of office hours and during periods of leave.
- To all people or entities who have signed a contract with Handicap International:
consultants, day labourers, Service Providers, partner organisations, etc.
***

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Institutional Policy

Anti-fraud, bribery,
and corruption policy
Federal Executive Division
December 2014 – Updated version in April 2019

IP 04
 Institutional Policy

Anti-fraud, bribery,
and corruption policy
1. Fraud, bribery and corruption: Obstructions to international aid
1.1 Definition of fraud, bribery and corruption
1.2 Their impact

2. Humanity & Inclusion and the fight against fraud, bribery,

and corruption
2
2.1 Principles
2.2 A pragmatic approach
2.3 Scope of the policy

3. Anti-fraud, bribery and corruption measures

3.1 Promoting an anti-fraud, bribery and corruption culture
3.2 Anticipation, dissuasion and detection
3.3 Reporting suspected cases
3.4 Reacting to reported cases and handling confirmed cases
3.5 Reporting and learning from experience
3.6 Controls and audits

4. Policy implementation and monitoring

4.1 Engagement by senior management
4.2 General mobilisation

5. Validation and dissemination of this policy

1.
Whilst fraud may be committed
unilaterally by an individual or group of
individuals, bribery requires a form of
Fraud, bribery and transaction with compensation in the
corruption: Obstructions form of a financial payment, payment
to international aid in kind, or other advantage. Cases of
— bribery may therefore include the acts
of soliciting, promising, offering, giving
or accepting an undue pecuniary or
1.1 Definition of fraud, other advantage, affecting the proper
bribery and corruption performance of duties and constituting
an act that is legally and ethically
When implementing its mission and
reprehensible.
activities, Humanity & Inclusion (HI) must
guard against the misappropriation of
its financial or material resources, and
1.2 Their impact
in particular against the risk of fraud,
bribery and corruption. 1.2.1
Fraud and various forms of bribery
Fraud pertains to acts which aim to
and corruption are a world-wide 3
obtain an undue material or moral
phenomenon found in all sectors
advantage by deliberately circumventing
of society. They pose serious
internal rules, contract rules or laws
problems for international cooperation
to the detriment of HI or a third party:
programmes, whether multilateral or
individuals, communities, organisations,
bilateral and in both development and
corporations or institutions.
humanitarian aid settings.
Bribery and corruption, associated
with other non-ethical conduct, cover 1.2.2
a range of practices including: Fighting fraud, bribery and corruption
at national and international levels
• conflicts of interest;
is primarily the responsibility of local
• fraudulent commissions;
and international authorities, including
• illicit gifts and invitations;
international cooperation agencies and
• extortion, theft or misappropriation
donors.
of materials or funds;
• facilitation payments;
1.2.3
• money laundering.
Conscious of the risks and issues
as well as
affecting their resources, image,
• abuse of power;
• nepotism and favouritism.
 interventions and the effectiveness In application of a principle of “zero
of their actions in support their tolerance”, context-appropriate actions
beneficiaries, non-governmental will be taken in response to any
organisations must tackle these suspected or confirmed incidents.
phenomena at their level.
2.1.2
HI’s anti-fraud, bribery and corruption
measures are adapted to the different

2. categories of prejudice that acts of fraud

and bribery cause:
Humanity & Inclusion • first and foremost to its staff;
and the fight against fraud, • to the beneficiaries of its projects
bribery, and corruption (should access to services or
— assistance be reduced or disrupted);
• and to the organisation and financial
equilibrium of its programmes.
2.1 Principles
Preamble 2.1.3
4 • Assuming its responsibilities as a At the operational level, in situations
non-governmental organisation of political violence or armed conflict,
engaged in international action; HI will increase its vigilance to prevent
• Concerned by the professional ethics its programmes’ resources from being
in this sector; misappropriated or instrumentalised to
• Working continuously to ensure that the benefit of armed groups or military
best practices are applied forces, regardless of their status or
to its operations and activities; motivations.
HI takes all possible measures to
prevent the risk of misappropriation, 2.1.4
inappropriate use of, or loss of the HI will not tolerate any form of
resources entrusted to it for the influence-peddling with local, national
implementation of its missions. or international public authorities or
with private bodies, whatever the
2.1.1 country and activity concerned.
HI will not tolerate any form of fraud,
bribery or corruption in the conduct of its
activities and has introduced measures
to reduce the risks and consequences.
2.1.5 2.2.2
HI cannot carry the whole burden These risks are monitored using
and responsibility for preventing and internal tools and mechanisms which
combating fraud, bribery and corruption cross-reference data published by
in the environment in which it operates. specialised bodies (such as Transparency
However, with regard to its own International) with incidents recorded by
activities, it will take all appropriate HI’s own services 1.
measures in accordance with its
prerogatives and means, with priority 2.2.3
given to the personal safety This risk monitoring enables HI to focus
and security of its staff. its anti-fraud, bribery and corruption
actions on those countries, staff and
2.1.6 beneficiaries most exposed to the risk
Furthermore, in its efforts to fight fraud, of such incidents. Priorities are then
bribery and corruption, HI will take care determined according to the size of
not to encourage a climate of suspicion the budget, the value of the resources
and mistrust. invested per country, programme and
activity and the level of reputational risk.

5
2.2 A pragmatic approach 2.2.4
HI’s anti-fraud, bribery and corruption
2.2.1
measures 2 cover:
HI adopts a pragmatic approach to
preventing and fighting fraud, bribery • staff recruitment and training,
and corruption, based on an analysis • project development,
which takes into account: • risk assessment,
• management and internal control,
• risks specific to each of the countries
• handling reported and confirmed
in which HI works or has offices;
cases,
• risks inherent in each function/
• and collaboration with other
profession exercised by its staff;
organisations in this domain.
• risks related to each sector of activity
in its intervention setting.

1. Existing and future tools will be regularly adjusted to the needs and reality of the situation.
2. These anti-fraud, bribery and corruption measures may overlap with other of HI’s policies
and provisions, such as the Protection of beneficiaries from sexual exploitation, abuse and
harassment (October 2011, Updated version in 2019), and the Logistics management, HI
policy, 2018.
 2.2.5 2.3.2
These measures are monitored and Operating partners
evaluated by in-house bodies which will (organisations and institutions)
apply all necessary corrective measures HI will take all the measures required by
in a timely manner and ensure any this policy with regard to information,
necessary support, or even protection, risk management, support and
for anyone who connected with the monitoring in its relations with its
exposure of reprehensible acts. operating partners which, while not
acting on HI’s behalf, interact with it
within the framework of a partnership
2.3 Scope of the policy agreement.

2.3.1
2.3.3
Members and staff
Companies and suppliers
This policy and its provisions apply,
HI will take all the necessary information
after any necessary adaptations, to:
and risk management measures with its
• HI’s permanent members and staff suppliers, as provided for in the contract
whatever their status (trustees, signed with these suppliers 3.
employees and volunteers);
6
• any person or associated or 2.3.4
intermediary body employed by HI Potential sanctions
and acting on its behalf. In the event of non-compliance with
Consequently, HI ensures that they are the provisions set forth in this policy,
aware of the existence of this policy and and depending on the gravity of the
its implications. situation, HI reserves the right to take
disciplinary measures, impose penalties,
terminate contracts and take legal
action with regard to those individuals
or organisations found to be responsible
of wrongdoing.

3. Notably, acceptance of the conditions in HI’s guidelines on good commercial practices for
companies submitting a tender.
3. 3.1.3
In particular, HI makes constant efforts
Anti-fraud, bribery to sensitive managers and supervisors
and corruption measures in order to avoid any potential or actual
conflict of interest between their private
—
interests and those of HI.
Responsibility for the implementation of
N.B.: For awareness-raising and training
this policy, via the mobilisation of staff
materials and documents presenting the
and the application of measures for
deontological commitments of members
preventing and fighting fraud, bribery
of HI, see the list of Guidelines on risk
and corruption lies primarily with the
management, internal control and
managers at head office, in the different
auditing.
entities of the HI Organisation and on its
programmes.

3.2 Anticipation, dissuasion

and detection
3.1 Promoting an anti-fraud,
bribery and corruption HI’s managers at all levels are
culture responsible for guaranteeing
7
management practices that effectively
3.1.1
limit opportunities to commit acts of
HI’s statutes, mission and strategy, as
fraud or bribery. They are specifically
well as its operating rules and internal
responsible for identifying the type and
control procedures, reinforced by this
level of risk to which our activities and
anti-fraud, bribery and corruption policy
resources are exposed and also have
are the main reference documents for HI
managerial responsibility for internal
members.
control.

3.1.2 They are advised on these matters by

HI regularly delivers awareness-raising, the support services specialized in these
training and information initiatives for areas.
its members and personnel at the Head
Offices of the entities in the HI network,
and on its field operation countries.
 N.B.: For response and handling
3.3 Reporting suspected
modalities, see the list of Guidelines on
cases
risk management, internal control and
3.3.1 auditing.
HI’s members and personnel are required
to report any suspected cases of fraud,
bribery or corruption, and may do so 3.5 Reporting and learning
safely and confidentially in accordance from experience
with the organisation’s guidelines on
All cases dealt with are recorded and
reporting and whistleblowing. These
a report is drawn up for the purposes
conditions notably set out forth the
of analysis. These reports are available
protection offered to people using the
for use, by the appropriate divisions
whistleblowing mechanism.
within the organisation and by relevant
bodies such as the Risk Management
3.3.2
Committee and the Audit Committee.
Reporting systems adapted to the
different situations encountered are also
made available to beneficiaries, partner
3.6 Controls and audits
organisations and suppliers.
8
3.6.1
N.B.: For reporting and whistleblowing
The implementation of checks and
mechanisms see HI’s Institutional
verification measures by managers are
Directive on Reporting suspicions on
an integral part of their internal control
fraud and abuse.
responsibilities. These measures are
decided as part of each division’s internal
planning process.
3.4 Reacting to reported
cases and handling
3.6.2
confirmed cases
Furthermore, internal audits are decided
Managers are provided with specific by the federal management bodies in
guidelines for use when investigating one of three ways:
or handling cases of fraud, bribery or
• as part of the annual audit plan
corruption. This handbook is for the
• chosen randomly
sole use of management staff or other
• organised in response to an alert.
qualified persons tasked with processing
these cases.
3.6.3 4.2 General mobilisation
The reports and recommendations are
Policy coordination requires the
analysed with a view to assisting the
mobilisation of all entities and divisions
entities audited and, more generally the
involved in:
organisation as a whole.
• carrying out risk evaluation and
N.B.: For internal control and audit
internal controls
mechanisms, see the list of Guidelines
• implementing and managing
on risk management, internal control and
programmes and support services
auditing.
• coordinating and enforcing the
different anti-fraud, bribery and
corruption measures

4.
• managing risk monitoring tools and
incidents relating to cases of fraud,
Policy implementation bribery or corruption
and monitoring • introducing measures to support,
guide, and ensure HI’s personnel are
—
capable of dealing with issues relating
To assist its personnel with the to fraud, bribery and corruption control
9
implementation and monitoring of this within the framework established by
policy, HI has put a number of coordination the organisation.
mechanisms and initiatives in place.

4.1 Engagement by senior

management
This policy will be coordinated,
monitored, assessed and updated at the
most senior levels of the organisation:
Executive Division and the Directorate by
delegation of authority from the Board of
Trustees.

The policy and its implementation will

be overseen by an Audit Committee
reporting to the Board of Trustees.
 5.
Validation and dissemination
of this policy
—
This version of the anti-fraud, bribery
and corruption policy cancels and
replaces the version adopted in 2012
and the revised version in 2014.

This document is for use by HI’s federal

network, Federation and national
associations, in its head office services
and in the field.

It is not for public distribution, but

may be communicated to bodies and
institutions in accordance with the
information and management measures
10
set out in the chapter “2.3: Scope of this
policy”.
This policy has been developed in
conjunction with other institutional
policies and directives, including:

• Reporting suspicions on fraud and

abuse, HI, 2018

• Code of conduct: Prevention of

abuse and safeguarding, HI, 2018

• Protection of beneficiaries from

sexual exploitation, abuse and
harassment, October 2011,
Updated version in 2019

All of the above are available

from on HInside.
11
Anti-fraud, bribery,
and corruption policy

This document outlines HI’s approach to

preventing and fighting fraud, bribery and
corruption. It contains a policy framework,
objectives and implementation measures.

Humanity & Inclusion

138 avenue des Frères Lumière
CS 78378
69371 Lyon CEDEX 08
France

[email protected]