Anti-Fraud, Anti-Corruption & Anti-Bribery Policy

01. Introduction

The Centre for Transnational Development and Collaboration (CTDC) is fully committed to conducting business with integrity, transparency, and accountability. This policy informs and guides all CTDC directors, trustees, employees, and associated persons on preventing and combating fraud, bribery and corruption in all our activities. CTDC abides by a zero-tolerance policy toward bribery and corruption throughout the organization and will take all necessary measures to create a culture that prevents such misconduct. Corruption and fraud threaten good governance, development, democracy and fair business practices, undermining the social justice and human rights work that are core to CTDC’s mission. Upholding the highest ethical standards is therefore essential for CTDC to achieve its objectives in a just, sustainable and effective way.

CTDC often works in countries and contexts (particularly in the Global South) where corruption risks are high, and we rely on institutional, donor and government funding for our projects. We must ensure that funds are spent transparently and properly at all times. Accordingly, CTDC takes a proportionate and practical approach to mitigating the risk of bribery and corruption in all locations where we operate. This includes robust financial controls and oversight to assure our partners, donors and beneficiaries that resources are managed with integrity and in line with our commitment to positive social change. All CTDC personnel and partners share responsibility for promoting a culture of honesty and fairness, and for using good judgment and common sense to uphold our ethical standards, even in challenging environments.

Legal Compliance: This policy is designed in accordance with UK laws and international best practices on anti-corruption. In particular, it aligns with the UK Bribery Act 2010 and the UK Fraud Act 2006, as well as guidance from the UK Serious Fraud Office (SFO) on anti-bribery compliance (including the SFO’s stance on facilitation payments and corporate hospitality). CTDC’s policies and procedures incorporate the six principles of adequate bribery prevention set out in UK Ministry of Justice guidance under the Bribery Act. By implementing these principles – from top-level commitment to ongoing monitoring – CTDC ensures it has “adequate procedures” in place to prevent bribery and to uphold corporate responsibility for ethical conduct. We maintain a zero tolerance stance: any form of fraud, bribery or corruption is strictly forbidden and will be addressed with the utmost seriousness.

02. Purpose and Scope

The purpose of this policy is to support all CTDC personnel in understanding their obligations and in making decisions that uphold our standards of integrity. It provides guidance on recognizing and avoiding fraudulent or corrupt behavior, and outlines the procedures for reporting concerns. This policy applies to all individuals at every level of CTDC – including directors, officers, employees (whether permanent, fixed-term, or temporary), interns, volunteers – and to any third parties associated with CTDC. Third parties include partners, agents, consultants, contractors, suppliers, or any person or entity performing services for or on behalf of CTDC (referred to as “associated persons”). The policy extends to all CTDC operations and projects worldwide, regardless of location or local business practices.

We also expect our partner organizations and consultants to abide by similar anti-fraud and anti-bribery standards when working with or for CTDC. Anti-corruption clauses are included in contracts, sub-grants, and Memoranda of Understanding, making our expectations clear. CTDC reserves the right to terminate relationships with any partner or associated person who fails to meet our anti-corruption standards. By following this policy, CTDC and its partners not only comply with the law but also demonstrate accountability to our donors, beneficiaries, and the public.

03. Definitions

For purposes of this policy, the following definitions apply (in line with UK statutory wording and guidance):

• Corruption: The misuse of entrusted power for private gain. This encompasses dishonest or fraudulent conduct such as bribery, embezzlement, fraud, extortion, nepotism or any abuse of position for personal benefit. Corruption undermines trust and fair dealing in both government and business contexts.
• Bribery: Offering, promising, giving, requesting, or accepting a financial or other advantage with the intention of inducing or rewarding improper performance of a duty or function. In other words, a bribe is an incentive or reward offered to someone (directly or through a third party) to influence them to act dishonestly or improperly. Bribery can take many forms, including cash payments, kickbacks on contracts, gifts, excessive hospitality, favors, or donations made to improperly influence a decision. Bribery is a criminal offense under the UK Bribery Act 2010, whether it involves public officials or persons in the private sector.
• Facilitation Payment: A small, unofficial payment (sometimes called a “grease payment”) made to a public official to secure or expedite a routine action (for example, to speed up issuing a permit or providing a service). Under UK law, facilitation payments are considered bribes and are illegal. The Bribery Act makes no exception for facilitation payments, even if they are permitted or common in some countries – they are treated as bribes and can result in prosecution in the UK.
• Fraud: Wrongful or criminal deception intended to result in financial or personal gain, or to cause a loss to another party. The UK Fraud Act 2006 defines fraud as an offense that can be committed by: (a) false representation, (b) failing to disclose information when there is a legal duty to do so, or (c) abuse of position. In all cases, the person acts dishonestly with intent to make a gain for themselves or another, or to cause someone else to lose money or property. Notably, no actual loss or gain needs to occur for the act to be fraudulent – even an attempted or halted fraud is an offense. Examples include falsifying expense reports, forging documents, misappropriating funds, or lying to obtain a contract or funding.
• Associated Person: Any individual or organization that performs services for or on behalf of CTDC. This broad term covers employees, subsidiaries, agents, intermediaries, consultants, contractors, volunteers, partners, or vendors acting on CTDC’s behalf. Under the Bribery Act, CTDC can be held liable if an associated person pays a bribe in order to obtain or retain business or a business advantage for CTDC. (However, CTDC has a defense if it can demonstrate that it had adequate procedures in place to prevent such bribery – hence the importance of this policy and its effective implementation.)
• Whistleblowing: The act of reporting concerns or suspicions of wrongdoing (such as fraud, bribery, safety violations, or other misconduct) by someone within the organization. A “whistleblower” is any person (typically an employee or insider) who raises a concern in good faith about improper conduct. Under UK law – specifically the Public Interest Disclosure Act 1998 – workers who blow the whistle on certain types of wrongdoing are legally protected from retaliation, so long as the disclosure is made in the public interest. (See the Reporting and Whistleblower Protection section below for details.)

Note on “Improper Performance”: Many of the terms above (especially bribery) involve the concept of someone improperly performing their duty. “Improper performance” means acting in breach of an expectation of good faith, impartiality, or trust. For example, if a public official is expected to award contracts impartially, it would be improper (and corrupt) for them to award a contract in exchange for a kickback. This policy and the law intend to prevent such deviations from proper duties.

04. Prohibited Conduct

CTDC strictly prohibits all forms of fraud, bribery and corruption. No CTDC director, employee, contractor or partner shall engage in any corrupt practice or any action that could be perceived as such. The following conduct is expressly forbidden under this policy (many of which are crimes under UK law):

• Bribery: No one acting for CTDC may offer, give, solicit or accept any bribe. You must never provide or promise anything of value to any person (whether a government official or a private business contact) with the intent of influencing them to improperly perform their duties. Likewise, you must never request or accept a reward in exchange for giving anyone an unfair advantage. This ban on bribes applies universally – there are no exceptions for “small” bribes or local customs. Even in countries where bribery might seem commonplace, CTDC personnel must refuse and report any such inducements.
• Facilitation Payments: All facilitation or “speed” payments are prohibited. Even if a minor payment is requested merely to expedite a routine government action (e.g. stamping a passport, releasing goods from customs), you must not pay. The UK Bribery Act does not allow facilitation payments – they are treated as bribes – and SFO guidance makes clear that companies and individuals can be prosecuted for making them. If you encounter demands for a facilitation payment, politely refuse and refer to CTDC’s policy. If you feel pressured, immediately report the incident to senior management for advice. (Any payment made under duress, where there is an imminent threat to personal safety, is addressed under “Extortion and Duress” below.)
• Kickbacks and Secret Commissions: It is prohibited to accept or give any kind of kickback or improper commission. A “kickback” is a form of bribe where a supplier or contractor returns a portion of contract fees to the person who awarded the contract (or their associate) as an illicit reward. For example, no CTDC staff member should ever receive money or anything of value from a vendor in return for giving them business; and no one acting for CTDC may offer such payments to secure CTDC contracts. All procurement and grant-making decisions must be based on merit, quality, and value, never on personal gain.
• Gifts and Hospitality: CTDC recognizes that exchanging modest gifts and hospitality can be a legitimate part of building business relationships. However, any gift, entertainment, travel, donation or hospitality that is excessive or given to influence a decision is strictly prohibited. Only token gifts and reasonable hospitality may be given or accepted, and never with an expectation of a favor in return. Gifts or hospitality that come with “strings attached” (an implied quid pro quo) are considered bribes and are not allowed. When dealing with public officials especially, err on the side of caution – even small gifts could be misinterpreted. All CTDC staff must adhere to any internal guidelines on gift value limits and disclosure of hospitality. If you are offered a gift or benefit beyond nominal value, or something feels improper, decline politely and notify your manager. Remember: genuine hospitality with no strings attached is legal, but lavish or frequent benefits intended to sway decisions are unlawful.
• Fraud and Deception: Any act of fraud, dishonesty or deception in the context of CTDC’s work is prohibited. This includes (but is not limited to) theft of funds or assets, embezzlement, false accounting, forgery of documents, and misrepresentation. Examples of fraud might include an employee falsifying timesheets or expense claims, a project partner misreporting how funds were used, or anyone fabricating data on a grant application or report. All financial transactions and records must be accurate and transparent. No secret or off-book accounts are permitted. Engaging in fraud is not only a violation of trust – it is also a criminal offense under the Fraud Act 2006 (punishable by up to 10 years’ imprisonment). CTDC will treat any attempted or actual fraudulent act as gross misconduct and grounds for immediate dismissal, as well as potential legal action.
• Conflicts of Interest: Conflicts between personal interests and CTDC’s interests must be avoided. All staff and associates must act in CTDC’s best interests and exercise objectivity in decision-making. You must not improperly use your position, or CTDC information or resources, for personal gain or to favor friends or relatives. Practices such as nepotism (favoring family or friends in hiring or contracting) or cronyism undermine fairness and are prohibited. If you have a potential conflict of interest – for example, a close relative is applying for a job or a contract with CTDC, or you have a financial stake in a supplier – you are required to declare it to management. CTDC will take steps to manage the conflict (such as recusal from decisions) to ensure transparency and integrity. Failing to disclose a conflict, or acting in CTDC matters for personal benefit, will result in disciplinary action.
• Money Laundering and Improper Use of Funds: CTDC funds and resources must never be used for unlawful purposes. Employees and partners should be alert to any signs that CTDC’s financial transactions could be misused to launder money or finance illegal activities. All payments must go through approved channels and be properly documented. Any suspicious requests (for example, pressure to make payments in cash, or to an unusual account) should be reported. CTDC will not facilitate tax evasion or any financial crime. We comply with all relevant anti-money laundering regulations.
• Retaliation: Retaliating against anyone who refuses to participate in bribery or who reports a concern under this policy is strictly forbidden. Any form of reprisal – such as demotion, harassment, or discrimination against a whistleblower – violates our values and UK whistleblower protection laws. (See Reporting and Whistleblower Protection below for more.) Managers must not pressure employees to achieve results at the cost of ethical conduct. CTDC’s commitment to integrity comes first, and employees will be supported when they do the right thing.

Extortion and Duress: CTDC recognizes that in rare situations, an employee or associate may face extortion – for example, a demand for a bribe coupled with an explicit or implicit threat to personal safety if the payment is not made. Personal safety and security must never be compromised. If a staff member genuinely believes they or others are in immediate danger (risk of loss of life, limb or liberty) unless a payment is made, then by all means they should make the payment to remove the threat. The UK Bribery Act allows an exception in cases of duress, as does English common law, recognizing that the payer had no free choice. However, any such incident must be reported to CTDC management as soon as it is safe to do so. CTDC will treat these situations with utmost understanding and assess them case by case. The individual will not face disciplinary action for a payment made under genuine duress. Our priority will be to get the person to safety and then consider what measures might prevent similar incidents. (If possible, also contact a director or the most senior available manager before making such a payment under threat – but only if it does not further endanger you.)

05. Roles and Responsibilities

Maintaining an honest, corruption-free organization is a collective responsibility. Specific roles within CTDC have the following responsibilities under this policy:

• Board of Directors and Top Management: CTDC’s Directors and Board set the tone from the top and are ultimately accountable for ensuring compliance with anti-fraud and anti-bribery laws. The leadership at CTDC is fully committed to tackling bribery and corruption at all levels. They must lead by example – demonstrating zero tolerance for unethical behavior – and foster a culture of integrity. Key duties of top-level management include: visibly promoting this policy (communicating CTDC’s anti-corruption stance to all staff and stakeholders), allocating adequate resources for compliance (e.g. training and risk management), and integrating anti-fraud controls into the organization’s governance and operations. The Board and Directors will identify and transparently address conflicts of interest in the organization’s governance, ensure that strong financial oversight and audits are in place to prevent fraud, and support enforcement of this policy (including sanctioning any errant staff or partners). Top management also ensures that anti-bribery procedures are kept up-to-date and effective. They will periodically issue statements reinforcing that CTDC conducts business fairly, honestly and openly, with zero tolerance for bribery. They will stress that any breach of this policy has serious consequences, and they will not hesitate to act against wrongdoing, regardless of a person’s position. In summary, CTDC’s leaders are champions of an ethical culture and are responsible for embedding anti-corruption values in the organization’s DNA.
• Managers and Supervisors: Managers at all levels must ensure their teams understand and comply with this policy. They serve as the first line of defense in prevention and detection of misconduct. Managers should create an environment where employees feel comfortable raising questions or concerns. Specific responsibilities include: implementing internal controls and checks within their department (for example, dual approvals on expenditures to prevent fraud), monitoring for any red flags of corruption, and promptly escalating any issues or reports of wrongdoing to the Directors. Managers must also ensure that new employees and contractors in their area receive appropriate induction on CTDC’s anti-fraud and anti-bribery expectations. If a team member seeks advice on an ethical dilemma or reports a suspected issue, managers must respond supportively and take it seriously. Managers are prohibited from turning a blind eye to misconduct – failure by a supervisor to report or address known violations will be treated as a serious matter. Ultimately, managers should reinforce the message that performance goals are never to be achieved by breaking the law or compromising integrity.
• All Employees and Volunteers: Every staff member and volunteer has a personal responsibility to uphold CTDC’s ethical standards. This means always acting honestly and reporting any suspected fraud, bribery or other wrongdoing. Employees must read and understand this policy (and participate in training provided) so they can recognize situations that may involve corruption or fraud. If you are unsure whether something is permitted, seek guidance from your manager or a Director – do not simply remain silent or go along with questionable activities. All employees are expected to: comply with all applicable laws and CTDC policies, follow the proper procedures for financial transactions (per CTDC’s financial policies), keep accurate records, safeguard CTDC’s assets, and never engage in or condone any form of corrupt behavior. Reporting – If you suspect a colleague, partner or anyone else is involved in fraud or bribery, or if you are approached with a bribe, you have a duty to report it (see the Reporting section below). CTDC will protect and support anyone who, in good faith, speaks up. Additionally, employees must cooperate fully with any investigations or audits related to compliance. Remember that even outside of work, your actions can reflect on CTDC – avoid any activities that could implicate the organization in impropriety.
• Associated Persons (Partners, Contractors, Consultants, Suppliers): CTDC expects that anyone doing work on our behalf shares our commitment to anti-corruption. We communicate this policy (or equivalent standards) to our partners and suppliers. Those who represent CTDC (even if not employees) are required to adhere to the principles of this policy and to avoid engaging in any conduct that would violate anti-bribery or fraud laws. Contracts and partnership agreements with CTDC include clauses forbidding corrupt practices and allowing CTDC to terminate the agreement if corruption is discovered. We may also require certain high-risk partners or contractors to undergo due diligence and/or sign a confirmation of compliance with our anti-bribery expectations. If an associated person (for example, a local partner NGO or an agent) is found to have paid a bribe or committed fraud in relation to a CTDC project, CTDC will consider that a serious breach of contract. CTDC will cease cooperation with any partner who fails to meet our anti-corruption standards, and may report the matter to authorities if appropriate. In sum, our zero-tolerance approach extends to all third parties representing CTDC – we choose to work only with those who demonstrate integrity.
• Compliance Officer / Point of Contact: (If applicable) CTDC may designate a specific person or team (for instance, a Compliance Officer, or the Finance Director, etc.) to oversee the implementation of this policy. That role includes keeping the policy updated with any legal changes, providing advice and training to staff, monitoring compliance (e.g. reviewing expense reports or gift registers), and investigating any reports of misconduct. All employees should know who this point of contact is for any ethics questions. In the absence of a dedicated compliance officer, the Co-Directors serve as the points of contact for compliance matters.

Everyone at CTDC, regardless of role, is empowered and expected to question potentially unethical practices. Remember: Integrity is a collective responsibility – if you see something, say something. By each of us fulfilling our responsibilities, we protect our organization’s reputation and the communities we serve.

06. Risk Assessment and Due Diligence

CTDC takes a risk-based approach to preventing fraud and bribery, recognizing that the level of risk can vary by project, country, and partner. We regularly assess the exposure of our activities to corruption risks and tailor our procedures accordingly, in line with the principle of proportionate procedures. This means that in areas or operations with higher risk, we implement stricter controls, whereas in low-risk environments a simpler approach may suffice – but in all cases, a baseline of compliance is non-negotiable.

Periodic Risk Assessments: CTDC will conduct periodic anti-corruption risk assessments, including as part of project planning and overall organizational risk management. These assessments consider both internal and external risk factors, such as:

• Country or Sector Risk: We evaluate the corruption level in countries where we operate. For example, if a country has known high corruption indices or weak enforcement of anti-bribery laws, CTDC recognizes that as a higher-risk context. Political instability or cultures of patronage can also increase risk. We also consider sector-specific risks (e.g. procurement in construction projects may have different risks than research collaborations).
• Partner/Third-Party Risk: We assess the integrity and capacity of partners, contractors or suppliers. A partner with robust governance and a strong track record may present low risk, while a new or smaller entity with less oversight may require more stringent checks. CTDC may perform due diligence checks (background research, reference checks, etc.) on potential partners, especially if they will manage CTDC funds or interact with officials on our behalf. We also look at the use of agents or intermediaries – any red flags (e.g. an agent with a history of unethical behavior) would lead us to avoid or monitor that relationship closely.
• Activity Risk: Some types of transactions are inherently higher risk – for example, large cash payments, procurement of big-ticket items, or engaging with government licensing processes. We identify where bribery or fraud could occur in our processes (e.g. in procurement, grant disbursement, expense reimbursements) and ensure controls are in place at those points (such as multiple approvals, documentation requirements, spending limits, audits).
• Internal Risk: We also consider internal factors such as the level of oversight, segregation of duties in financial processes, and any past incidents of fraud or weakness in controls. For instance, CTDC being a relatively small organization with a non-complex structure may mean fewer layers of oversight, which we address by strict separation of roles and external auditing.

Due Diligence on Third Parties: CTDC performs due diligence proportional to the identified risks when engaging third parties. This can include: checking a prospective partner’s ownership, reputation and sanctions status; inquiring into their internal anti-corruption measures; and ensuring they understand CTDC’s expectations. Where appropriate, CTDC may ask partners to certify their compliance or even conduct an on-site visit or financial review. For example, if CTDC works with a partner in a high-risk environment who will handle grant funds, we may require detailed financial reports and backups before replenishing funds, or we might opt to reimburse costs rather than advancing funds if their controls seem weak. Conversely, with a well-established partner that has strong controls, we can rely more on their systems once trust is established. CTDC will update its due diligence approach based on monitoring and evaluation findings during the partnership.

Integration with Project Processes: The outcome of risk assessments will inform project planning. If a project is deemed high-risk (e.g. operating in an area with widespread bribery), the project plan will include enhanced measures – such as extra training for staff, closer expense monitoring, or requiring multiple signatures on payments. We will also incorporate anti-corruption criteria in program audits and evaluations, to verify funds are used as intended.

Documentation: All risk assessments and due diligence steps taken should be documented appropriately. This not only helps in decision-making but also serves as evidence that CTDC is meeting the “adequate procedures” expectation under the UK Bribery Act to prevent bribery. If a particular engagement or transaction is approved despite some risk, the rationale and mitigating measures will be recorded.

In summary, CTDC commits to knowing who we are dealing with, understanding the environment we operate in, and taking sensible precautions to prevent fraud or bribery before they occur. This proactive approach is key to reducing opportunities for corruption. Should risks change or new risks emerge, CTDC will reassess and adjust its procedures in a continuous improvement cycle.

07. Training and Communication

Clear communication and knowledge are critical for an effective anti-fraud and anti-corruption program. CTDC is dedicated to ensuring that its commitment to integrity is well known both internally and externally. We strive to embed an ethical culture through ongoing training and open dialogue.

Employee Training: All CTDC employees and long-term contractors will receive training on this Anti-Fraud and Anti-Bribery Policy and related procedures. New staff are introduced to CTDC’s ethical standards during orientation. Periodic refresher trainings or workshops will be conducted to reinforce understanding of key risks and to keep staff updated on any changes in law or policy. Training will cover practical topics such as how to identify red flags of fraud or bribery, how to respond if offered a bribe, case studies relevant to CTDC’s work, and the correct way to report concerns. Specialized training may be provided to those in higher-risk roles (for example, procurement officers or field managers handling cash) to ensure they have the skills to manage those risks. We also incorporate scenario-based discussions to encourage a “speak up” culture – making it clear that raising concerns is encouraged and safe.

Internal Communication: CTDC’s leadership will regularly communicate the importance of anti-corruption compliance. This can include management messages or reminders in staff meetings, emails from the Directors reiterating our zero-tolerance stance, and sharing of any relevant updates (such as a new law or a lesson learned from an incident elsewhere). Top-level communications will highlight: CTDC’s commitment to carrying out business fairly, honestly and openly; our zero tolerance for bribery; the consequences of policy breaches; and the avenues for reporting suspicions. The Directors or Board may issue an annual statement or include in the annual report a note on CTDC’s anti-corruption efforts, which helps set the tone at the top.

We ensure that anti-corruption expectations are clearly communicated to all audiences we engage with:

• Staff: Every employee must read and acknowledge this policy (we may require a signed confirmation or a training completion certificate). The policy document is readily accessible (e.g., on our internal drive or handbook). We may display key principles on office notice boards or include reminders in payslips/newsletters.
• Partners and Associated Persons: We share relevant parts of this policy or our Code of Conduct with partners, vendors, and consultants. In meetings with new partners, we verbally communicate our stance on fraud and bribery to ensure mutual understanding. Any subcontractor or agent representing CTDC will be informed of the standards we expect.
• Donors and Public: CTDC is proud of our commitment to transparency and anti-corruption, and we communicate this in our external relations. For instance, we may publish our anti-corruption policy on our website, and emphasize to funders that we have strong controls in place. In public presentations or community meetings, CTDC staff should feel empowered to mention our zero-tolerance approach as part of demonstrating accountability.

Encouraging a Speak-Up Culture: A core message in all communication is that integrity is everyone’s responsibility and that all personnel are encouraged to speak up if something seems wrong. CTDC wants an atmosphere where questions or concerns can be raised without fear. This is continuously emphasized in trainings and internal memos. Managers are coached to receive concerns appreciatively and to praise (not punish) vigilance. We also reassure staff that they will be protected and supported if they refuse to participate in wrongdoing or report a problem (see Whistleblower Protection below). By making these values explicit in all our communications, we aim to deter misconduct (employees and partners clearly know where CTDC stands) and to ensure problems are surfaced early rather than hidden.

In summary, CTDC integrates anti-fraud and anti-bribery messaging into the fabric of our organizational communications. We treat ethics not just as a legal compliance checkbox, but as a fundamental part of who we are and how we operate. Through regular training and open communication, we empower our team and partners to uphold our standards and to be vigilant guardians of CTDC’s integrity.

08. Monitoring and Review

Continuous improvement and vigilance are essential in the fight against fraud and corruption. CTDC will monitor the implementation of this policy and review its adequacy on a regular basis to ensure it remains effective and up-to-date.

Ongoing Monitoring: CTDC will monitor compliance with anti-fraud and anti-corruption measures through both internal and external mechanisms. Internally, our finance team and management will conduct routine checks – for example, reviewing financial transactions, verifying supporting documents, and ensuring reconciliations are done – to detect any irregularities. We will also track any incidents or allegations of misconduct to identify patterns or areas of weakness. If any red flags are spotted (such as unexplained accounting entries, unusual payment requests, or repeated complaints about a certain process), management will investigate further. In addition, CTDC’s external auditors (or any donor audits) play a role in reviewing our controls and might flag concerns that need addressing. Project reports will include a section on whether any fraud or corruption issues arose and how they were handled, as part of our transparency to donors.

Whistleblower Reports: As part of monitoring, CTDC will keep a log of all reports or allegations of fraud/corruption (from whistleblowers or other sources). Each case will be tracked until resolution, ensuring proper investigation and follow-up. The volume and nature of such reports will be periodically analyzed (by the Board or audit committee, if one exists) to see if certain departments or geographies have higher incidents and why. Even if no reports are received, that will be noted – a complete lack of reports may warrant checking if staff are truly aware of the reporting channels or perhaps reluctant to come forward (which we would address through more engagement).

Evaluation and Lessons Learned: After any corruption-related incident or near-miss, CTDC will evaluate what went wrong and update procedures accordingly. For example, if an embezzlement scheme is uncovered in a project, after dealing with it, we will review how our controls failed to prevent or detect it sooner and strengthen those gaps (be it stricter approval processes, more frequent audits, etc.). Similarly, if someone was able to offer a bribe to a CTDC partner, we will examine our partner vetting and training procedures. CTDC also stays informed about best practices and developments in compliance – for instance, any new guidance from the Serious Fraud Office or industry benchmarks – and will adapt our program as needed.

Policy Review: This policy document itself will undergo a formal review on an annual basis (or more frequently if significant legal changes occur or if an incident highlights an urgent need). The Directors (or designated Compliance Officer) will ensure that the review happens and will involve input from relevant staff. Updates may be made to reflect changes in legislation (e.g., new guidance from the SFO or amendments to the Bribery Act/Fraud Act), organizational changes (new roles or procedures), or lessons learned from our monitoring efforts. Any amendments to the policy will be clearly communicated to all staff in a timely manner – for example, via email and a briefing session – to ensure everyone is aware of the new provisions. The updated version will replace the old one in our official files, and staff may be asked to re-acknowledge the policy if substantial changes are made.

Independent Oversight: CTDC’s Board (or an Audit Committee, if in place) will oversee the effectiveness of our anti-corruption program. They will review summaries of risk assessments, any incidents that occurred, and management’s responses. If needed, the Board may commission external reviews or audits of CTDC’s anti-fraud controls to get an objective evaluation. We are open to feedback from donors or partners as well, since they might observe issues we can improve on.

By diligently monitoring our operations and updating our strategies, CTDC aims to stay ahead of emerging fraud and corruption risks. This proactive stance helps ensure that our “adequate procedures” remain truly adequate, and that we maintain the trust of those who rely on our integrity.

09. Reporting and Whistleblower Protection

CTDC strongly encourages all staff and partners to report any suspicions or evidence of fraud, bribery, corruption or any violation of this policy. Early reporting and intervention can significantly limit harm and facilitate prompt resolution. We are committed to providing a safe and confidential environment for whistleblowers to come forward without fear of retaliation.

Reporting Channels: If you become aware of a potential issue – no matter how small it may seem – you should report it as soon as possible. Multiple channels are available to raise concerns, so you can choose the one you feel most comfortable with:

• Line Management: In most cases, you may report directly to your immediate supervisor or manager. They are expected to listen and take your concern seriously. Managers will escalate the report to the Directors as appropriate.
• Direct to Directors: If the issue involves your management, or you feel uncomfortable going through the normal line, you can report directly to one of the Co-Directors of CTDC. You may do this in person, via phone, or by email. (We will provide the contact details internally.)
• Designated Officer or Email: CTDC may establish a designated confidential email (e.g., [email protected]) or assign a particular person (e.g., a Compliance Officer or a Board Audit Committee Chair) to receive reports. Check the latest staff guidance for the current reporting contact. This channel might be useful if you wish to bypass line management entirely.
• Anonymous Reporting: While we encourage you to identify yourself (so we can follow up and provide support/protection), we understand there may be cases where you prefer to remain anonymous. If we have an anonymous hotline or third-party service, that information will be made available to all staff. Even an unsigned note or message providing details is better than silence. CTDC will still investigate anonymous reports to the extent possible, though please note anonymity can make it more difficult to ask follow-up questions or give feedback.
• External Reporting: Our policy is to handle matters internally when possible. However, UK law recognizes that whistleblowers may also go to certain external authorities (known as “prescribed persons”) and still be protected – for example, reporting bribery or fraud to the Serious Fraud Office, the police, or regulatory bodies. If an issue is extremely serious and you believe internal channels are not appropriate or have failed, you may contact a relevant authority directly. We urge you to seek advice before doing this, to ensure you are protected under whistleblowing laws and not disclosing confidential information improperly. Organizations like Protect (formerly Public Concern at Work) can provide confidential advice to whistleblowers in the UK.

Non-Retaliation Guarantee: CTDC absolutely forbids any form of retaliation against anyone who reports a concern in good faith or refuses to engage in wrongdoing. Retaliation means any detrimental treatment, such as firing, demotion, loss of benefits, harassment, exclusion, or intimidation of a whistleblower. Under the Public Interest Disclosure Act 1998, whistleblowers are protected by law from unfair dismissal or detriment for raising qualifying concerns. CTDC embraces these protections fully. Any employee, no matter their rank, who retaliates against a whistleblower will face disciplinary action, which could include termination. If you believe you are experiencing retaliation, report it immediately through one of the channels above – that itself is a serious issue.

We also protect those who refuse to participate in an unethical or illegal act. For instance, if you decline to pay a bribe that your supervisor subtly encouraged, and you then feel you are being penalized for it, inform senior management. You have the same legal protections as a whistleblower in such scenarios of “protected refusal.”

Confidentiality: Reports of suspected wrongdoing will be handled in the strictest confidence. When you report an issue, we will limit knowledge of your identity and the information to those who need to know in order to investigate and address the problem. We will never reveal a whistleblower’s identity without their permission unless required by law (for example, if legal proceedings demand it, and even then we would seek to inform you beforehand). You can also request to keep your identity unknown even internally – raising a concern confidentially means you give your name but ask that only the people investigating know it. We will respect and safeguard that confidentiality. Of course, you also have the option to report anonymously as noted, though as mentioned, doing so may limit our ability to seek clarification and give you feedback.

Investigation of Reports: Every report of alleged fraud, bribery or other misconduct will be reviewed and, if credible, investigated promptly and appropriately. Typically, the Directors will assign an impartial person or team (which may include someone from outside the immediate work unit, or an external investigator if needed) to look into the matter. The investigation will aim to determine the facts through steps such as reviewing documents, analyzing transactions, and interviewing individuals involved. The whistleblower’s information will be taken seriously and evaluated along with other evidence. We strive to complete investigations in a timely manner, given the complexity of the case – the whistleblower may be informed of an estimated timeline and will receive acknowledgement that their report was received (usually within a few days). During the investigation, the whistleblower will be treated with respect and not exposed to liability; they might be asked for further information, but they are not expected to prove the wrongdoing – that is CTDC’s responsibility to investigate. If the allegations are substantiated, appropriate action will be taken (as outlined in the next Enforcement section). If an allegation is not substantiated, we will close the matter, but the whistleblower will not be penalized as long as the report was made in good faith – we recognize that someone can be mistaken and still be protected.

After the investigation, CTDC (through a manager or Director) will, to the extent appropriate, inform the whistleblower of the outcome. There may be cases where we cannot share full details (e.g. if it involves confidential personnel decisions), but we will strive to give some reassurance that the matter was addressed. If the whistleblower is not satisfied that the issue has been properly resolved, they are free to escalate it (for example, to the Board Chair) or seek external advice.

Malicious or False Reports: To maintain the integrity of our whistleblowing system, CTDC must also guard against abuse of the process. While we welcome genuine reports (even if ultimately unproven), deliberately false or malicious allegations are not acceptable. If an investigation reveals that a report was made with knowledge that the allegation was untrue, or with intent to harm someone’s reputation without cause, the person who made the false report will face disciplinary action. This is in line with our general disciplinary policy for misconduct. However, note: we will never punish someone who had reasonable grounds to suspect wrongdoing, even if the investigation doesn’t find evidence to substantiate the concern. We want to ensure no one is dissuaded from coming forward out of fear of being wrong.

In summary, CTDC is committed to an environment where concerns can be raised freely, investigated fairly, and resolved justly. Whistleblowers play a critical role in protecting our organization and its mission. We want every employee to feel empowered to be the “eyes and ears” of integrity. By reporting problems, you are doing the right thing and helping CTDC uphold its values – and you have our full support in doing so.

10. Enforcement and Consequences

CTDC will enforce this policy rigorously. Violations of the Anti-Fraud, Anti-Corruption & Anti-Bribery Policy are considered serious misconduct and will result in appropriate disciplinary and legal action. The potential consequences reflect the severity of these offenses:

Internal Disciplinary Action: If an investigation finds that an employee has engaged in fraud, bribery or any form of corruption, CTDC will take decisive disciplinary measures. This may include immediate termination of employment (for gross misconduct) and, if appropriate, legal action to recover any losses. Lesser sanctions (such as a formal warning, demotion or suspension without pay) might apply in cases of minor or inadvertent breaches, but wilful acts of corruption will typically result in summary dismissal. Managers or supervisors who knew of misconduct and failed to report or address it may also face disciplinary action. In all cases, disciplinary proceedings will be conducted in line with CTDC’s HR policies and employment law. The individual will have an opportunity to respond to allegations before decisions are made, but if wrongdoing is confirmed, CTDC’s stance is firm. No employee – regardless of position or tenure – is exempt from consequences under this policy. The loss of a job and reputation is a very real outcome for anyone who chooses to violate our trust and break the law.

Contractual Remedies for Partners: For external partners, contractors or vendors, any breach of this policy (such as paying bribes on a CTDC-funded project or committing fraud with CTDC funds) will trigger remedies available under the contract. This includes possible termination of the contract or partnership agreement for cause, and may also include claims for damages or repayment of misused funds. CTDC will discontinue any collaboration with partners found to be involved in corruption. We will also communicate to our donor(s) and other relevant parties if such an incident occurs, demonstrating our accountability and the actions taken. In some cases, we may ban the offending party from future CTDC opportunities and inform other organizations (where appropriate and lawful to do so) of the issue, in order to prevent further abuse in the sector.

Referral to Law Enforcement: CTDC will report criminal offenses to the appropriate authorities when warranted. Fraud and bribery are crimes, and CTDC will not hesitate to involve law enforcement (such as the Serious Fraud Office, City of London Police, or National Crime Agency, depending on jurisdiction) if we uncover evidence that these have occurred. Particularly, any instance of bribery of a foreign public official, large-scale fraud, embezzlement of donor funds, or similar grave matters will be reported. We recognize that as a UK-incorporated organization, CTDC could itself face liability for failing to prevent bribery (the corporate offense under Section 7 of the Bribery Act) if we do not respond appropriately. Cooperation with authorities is also a factor that is looked upon favorably if the organization were ever under scrutiny. Therefore, CTDC will cooperate fully with police/SFO investigations, and we may choose to self-report serious issues to the SFO or other regulators in order to transparently address them. Law enforcement actions could lead to prosecution of the individuals involved and possibly of CTDC as an entity, so we view external reporting as a critical step in the most serious cases.

Legal Penalties: It is important for all staff and associates to understand that violating anti-bribery or anti-fraud laws carries severe penalties. Under the UK Bribery Act 2010, individuals can face up to 10 years imprisonment and an unlimited fine for offenses like giving or receiving bribes. Companies found guilty of bribery offenses can also face unlimited fines, and can be barred from public contracts. Under the UK Fraud Act 2006, fraud by false representation, by failing to disclose information, or by abuse of position are each punishable by up to 10 years in prison and/or a fine. These penalties underscore that engaging in such conduct is not worth the risk by any measure. Even beyond formal penalties, any association with corruption can cause immense damage to one’s career, future job prospects, and personal reputation – not to mention the harm done to the communities we serve and the mission we stand for. There is simply no place for fraud or bribery in CTDC, and those who commit it will be held accountable.

Recovery of Losses: In cases of fraud or embezzlement that result in financial loss to CTDC or our donors, we will take action to recover assets. This could include civil legal action against the perpetrator (such as suing for damages or initiating proceedings to confiscate assets gained from the misconduct), and/or making insurance claims if applicable. Any funds recovered will be returned to the proper purpose (for example, back to the project or donor if required). While prevention is the goal, CTDC will seek restitution if a loss occurs.

Improvement of Controls: Enforcement isn’t only about punishment; it’s also about learning lessons. After any incident, CTDC’s management will review what went wrong and strengthen controls to reduce the chance of recurrence. We treat near-misses and breaches as opportunities to reinforce our systems and training (as noted in the Monitoring section). Our stakeholders – including employees – will be informed of any key changes in procedure that come about as a result.

Documenting the Outcome: All enforcement actions taken (internal disciplinary, contract termination, police report, etc.) will be documented by the Directors or HR in an investigation report or case file. This record will be kept confidentially but may be shared with relevant bodies if required (e.g., with a donor or law enforcement). Documentation ensures there is an audit trail of our response and that we can demonstrate compliance with our legal obligations.

CTDC wants to emphasize that while the consequences of misconduct are severe, our sincere hope is never to have to enforce them. Our aim is that through awareness, training, and a strong ethical culture, no one at CTDC will engage in behavior that necessitates such action. By making the potential repercussions clear, we hope to deter any temptation and underscore the seriousness with which we view these issues. We are determined to maintain an organization that is not only compliant with the letter of the law but truly lives by the spirit of integrity.

This policy will be distributed to all current employees and made available to all new hires and associated persons. All are required to adhere to its provisions.

For any questions about this policy or its interpretation, please contact the Co-Directors or the designated Compliance Officer.

11. Version Control

• Policy Title: Anti-Fraud, Anti-Corruption & Anti-Bribery Policy
• Version: 2.0
• Date of Last Revision: November 25, 2025
• Next Review: November 2026 (or earlier if required)
• Supersedes: Version 1.0 (dated January 2021)

12. References

Relevant UK legislation and guidance informing this policy include the Bribery Act 2010, the Fraud Act 2006, the Ministry of Justice’s Guidance on the Bribery Act (2011) outlining six principles of adequate procedures, and guidance/Policies from the UK Serious Fraud Office on corporate anti-corruption compliance (including statements on facilitation payments and business expenditures). Key provisions have been incorporated to ensure CTDC’s policy meets or exceeds these requirements, such as the statutory definitions of bribery, the corporate offence of failure to prevent bribery and its adequate procedures defense, the prohibition of facilitation payments, the Fraud Act’s definition of fraud offenses, and the whistleblower protections under the Public Interest Disclosure Act 1998. This alignment with UK frameworks ensures that CTDC’s policy is legally robust and comprehensive. All CTDC personnel are expected to not only follow the policy but also uphold the underlying laws and principles it is based on.