Address: FAME Hub, Suite D7, Halima Plaza, Plot 1496Balanga Street, Garki Area 11, Abuja, Nigeria
A Not-Profitable Organisation set up to formulate programmes through several initiatives to mentor, empower and advocate for women and girls.
FAME foundation was established to solicit, encourage and advance the social, emotional and economic wellbeing of women and girls as well as formulate programmes within the framework of national development plan with a view to enhancing the participation of women and advocate for gender parity in the society. FAME foundation firmly believe that the entire nation, businesses, communities and groups can benefit from the implementation of programs and policies that adopt the notion of women empowerment.
Anti- Fraud, Bribery, and Corruption Policy
FAME Foundation’s Anti- Fraud, Bribery, and Corruption Policy is designed to promote an anti- fraud culture and consistent organizational behavior across the organization when dealing with cases of suspected fraud, bribery, or corruption. It sets out responsibilities for fraud prevention and detection and provides clear guidelines and procedures for reporting cases of suspected fraud and corruption and for the conduct of investigations.This policy applies to the FAME foundation Board of Trustees, Senior Management, all other staff, and volunteers.
FAME Foundation requires all staff at all times to act honestly and with integrity and to safeguard the resources for which they are responsible. The FAME foundation policy stipulates that:
FAME foundation also expects that individuals (e.g. any suppliers, contractors, and service providers) that it interacts with will act towards the organization with integrity and without thought or actions involving fraud. Where relevant FAME foundation will include appropriate clauses in its contracts about the consequences of fraud, bribery, and corruption; evidence of
such acts is likely to lead to a termination of the particular contract or termination of an individual’s affiliation to the organization and may lead to prosecution.
The Fraud Act 2006 created a new general offense of fraud with three possible ways of committing it.
Corrupt Practices and other Related Offences Act 2003 established three main offenses of fraud, all of which carry a maximum sentence of 10 years and/or an unlimited fine. The offenses are:
The following actions are among those which fall within the definition of fraud:
Corruption is the misuse of power for private gain.
The Bribery Act 2010 makes bribery and corruption a criminal offence and holds companies and organizations liable for failing to prevent acts of bribery or corruption by those working for or on its behalf, no matter where the act takes place.
This policy applies to allFAME foundation’s directors and staff, working on behalf of the organization.
FAME foundationexpects high standards of conduct and probity from all of its directors and staff and requires them at all times to act honestly, with integrity and to safeguard the resources for which they are responsible. The company also expects its suppliers, delivery partners and sub-contractors or vendors to maintain the same high standards of conduct and probity.
FAME foundationis committed to developing an anti- fraud culture and actively seeks to deter and prevent fraud and corruption by ensuring that risks are identified and managed effectively. The company will not accept any level of fraud, bribery or corruption and will investigate
thoroughly all suspected cases. Staff involved in an impropriety of any kind will be subject to the company’s disciplinary procedures and legal action will be taken where appropriate.
To ensure that this policy is implemented effectively, FAME foundation will:
The Finance officer holds overall responsibility for FAME foundation’s corporate anti- fraud policy and procedures. They are responsible for establishing and maintaining a sound system of internal control to manage the whole range of risks that FAME foundationfaces. A five- man audit committee, made up of at least 3 non-executive directors appointed by the Board of Trustees, is responsible for reviewing the effectiveness of the organization’s internal control and risk management systems, as well as the organization’s procedures for detecting fraud.
The Executive Director is responsible for:
The Finance Officer is responsible for:
The Organization Risk Officer is responsible for:
place and meet the contractual requirements relating to the prevention of fraud and dealing with suspected incidents of fraud
The Media and Communications Officer is responsible for:
Any employee who is, or might be influenced by personal considerations which may hinder objective decision- making must seek advice from an appropriate senior officer. Employees and their families must not accept, directly or indirectly, any money, gifts or hospitality which could influence or appear to influence decisions they make on behalf of the organization. Staff responsible for the purchase of supplies, equipment or services must take particular care to ensure that there can be no criticism that unequal treatment has been given to suppliers involved in tendering processes, through the acceptance of gifts or other benefits.
Employees who are offered a gift as an inducement for preferential treatment must decline or return it as appropriate, with a suitably courteous letter explaining the organization’s policy. Employees should not give any gift or hospitality with the expectation that they and/or the
company will benefit from it, since this may constitute a bribe. The acceptance and/or offer of small gifts and/or casual hospitality such as business lunches, dinners or invitations to events, is acceptable within reasonable grounds, as long as it is a normal and appropriate expression of business courtesy and that the recipient is not placed under any obligation.
If a member of staff is in any doubt as to the propriety of giving or receiving any gift or hospitality then he/she must consult his/her line manager.
Contacts with and/or gifts to or from national or local government officials can be particularly sensitive. Employees must not offer or provide, either directly or indirectly, any pecuniary or other advantage to or for a public or corporate official in order to obtain or retain business or secure any improper business advantage. Any employee who is asked by a government or corporate official to circumvent these rules must immediately report the matter to Executive Director.
Employees should not make any contributions to either individual politicians or political parties in order to secure political or commercial influence on behalf of the organization. (This does not preclude private donations to political parties made by individual employees which otherwise would be lawful).
FAME foundationexpects its vendors and delivery partners to maintain high standards of conduct and probity and to have in place anti-fraud processes similar to that of the organization. All of FAME foundation’s staff should therefore be required to:
Where necessary, FAME foundationwill assist providers in developing appropriate control systems to prevent and detect fraud when appropriate. Where a potential vendor is judged to have inadequate processes and is unwilling to commit tothe standards of the organization, FAME foundationwill not do business transactions with such vendors.
Fraud may be discovered in a number of ways, including the following:
Staffs are encouraged to report any suspicion of fraud, bribery or corruption or any other form of malpractice. The Confidential Disclosure Policy makes clear that staff can report suspicions confidentially and without fear of victimization or subsequent discrimination or disadvantage, whatever the outcome of an investigation.
This policy is communicated to all staff via the organization’s platforms, including the social media accounts.
Internal control systems are subject to regular audits to provide assurance that they are effective in countering fraud, bribery and corruption.
The company’s external auditors review the internal financial control systems on an annual basis as part of their statutory audit. Any control issues arising or recommendations for improvement are set out in the Key Issues Memorandum which is presented by the external auditors to the Audit Committee.
Internal audits of the organization’s financial controls are carried out periodically by senior members of the finance team and the Organization Risk Officer who are not directly involved in the area being reviewed.
This policy is reviewed every year or in the event of any change in related government policy.
Any suspicion of fraud, bribery and corruption (whether perpetrated by a member of FAME foundation staff or by a third party) must be reported without delay to a manager who without delay should escalate to the Organization Risk Officer. No investigations should be undertaken at a local level by managers or other staff. Internal investigations could be counterproductive to the investigative process and hamper efforts to promote an independent and transparent process.
At any time during an investigation, the initial risk status may escalate (or deescalate) at which time the Organization Risk Officer will notify, in liaison withOperations Manager and the Executive Director.
The Risk Management Incident Group comprises key company stakeholders best placed to advise, direct and manage serious incidents.All members or a combination of representatives may be called upon.
The Risk Management Incident Group
The Risk Management Incident Group will determine what immediate action should be taken, for example, whether the matter should be immediately reported to the police and how the investigation will proceed.
The Organization Risk Officer should maintain a chronological record of events, giving a full explanation of each action and event during the course of the investigation. As considerable time may elapse between the start and conclusion of the investigation, it is important that a detailed record is maintained to aid recall to all relevant events. A successful criminal prosecution may also depend on these details. The following should be logged:
Where there is a possibility of subsequent criminal proceedings, the Risk Management Incident Group will nominate the Organization Risk Officer to refer the matter to the police and seek advice from them on the conduct of internal enquiries, to ensure that any potential criminal case is not prejudiced.
The Organization Risk Officer will need to interview members of staff under investigation and other members of staff who may be witnesses to or able to help establish the facts. During interviews the investigating officer should adopt the following best practice:
may decide the appropriateness of sharing these documents with other company employees i.e. the Human Resource Officer.
Where initial investigation provides reasonable grounds for suspecting a member of staff of fraud, theft, bribery or corruption, the Risk Management Incident Group will take steps to prevent any further loss. It may be appropriate to suspend the suspect(s) pending the outcome of the investigation.
In these circumstances, the suspect(s) should be:
Post consultation with the Risk Management Incident Group, notification to the funding organization about actual or suspected fraud should commence where necessary.FAME foundation’scontractual obligations with regards to reporting are detailed within the various contracts and guidelines. The Operations Manager hold copies of these and must follow the required protocol, liaising with contract managers throughout the process.
Any media response plan should be consented to by the Risk Management Incident Group. Enquiries from the media in respect of any case of fraud, theft, bribery or corruption should be referred to the Media and Communications Officer who will make any statement to the media.
Address: FAME Hub, Suite D7, Halima Plaza, Plot 1496Balanga Street, Garki Area 11, Abuja, Nigeria