Anti-Fraud Policy - საერთაშორისო გამჭვირვალობა - საქართველო

Anti-Fraud Policy

12 October, 2012

Transparency International  Georgia

Antifraud policy 



     1. General Provisions

Transparency International Georgia (TI Georgia) is committed to maintaining high ethical standards in the organization and to implement a zero tolerance policy, recognizing that fraud and corruption is contrary to fundamental values of integrity, transparency and accountability. TI Georgia, will spare no effort to identify and promptly investigate any suspected fraudulent or related dishonest activity against the organization or other parties with whom TI Georgia has dealings. The organization commits to take appropriate disciplinary and legal actions including the possibility of termination of employment, restitution, and forwarding information to the relevant authorities for prosecution.

     2. Scope

This policy shall apply, unless the context otherwise requires, board members, management, employees, consultants, experts, volunteers, Interns and other representatives of TI Georgia.

     3. Definition of Terms

Fraud – Fraud is any intentional act or omission designed to deceive others, resulting in the victim suffering a loss and/or the perpetrator achieving a gain. Dishonest or fraudulent activities include, but are not limited to, the following: forgery or alteration of documents (checks, bank draft, and timesheets, invoices, agreements, etc.) or bank accounts belonging to the TI Georgia, misrepresentation of information on documents, misappropriation of funds, supplies, or assets, theft, disappearance, or destruction of assets, improprieties in the handling or reporting of money or financial transactions, authorizing or receiving payments for goods not received or services not performed, authorizing or receiving payment for hours not worked, inappropriate use of the company’s records and disclosing confidential and proprietary information to outside parties.

Corruption/bribery – the offering, promising, giving, accepting or soliciting of money, a gift or other advantage as an inducement to do something that is illegal or a breach of trust in the course of carrying out an organization’s activities and the failure to disclose an interest in order to gain financial or other type of material gain.

Extortion – the unlawful use of one’s position to obtain money through coercion or threats. Facilitation payments small or big unofficial payments made to secure or expedite the performance of a routine or necessary action to which the payer of the facilitation payment has legal or other entitlement.

Gifts and hospitality – inappropriate hospitality (tickets for major events, holidays etc.) or extravagant and inappropriate gifts when disguised as bribes that are intended to induce improper behavior.

Whistleblowing – the reporting by employees, ex-employees, Board members, Interns, volunteers, representatives of the organization, contractors, or any other person outside the organization of wrongdoing such as fraud, corruption, any form of malpractice, or any other illegal or unethical act either on the part of management, board or by employees.

     4. Responsibilities of employees and representatives of TI Georgia

No one shall engage in acts of fraud, corruption, extortion or use of illegal payments in order to facilitate the performance of a routine or necessary action.

No person who acts for, or on behalf of, TI Georgia shall accept any gift, hospitality/entertainment, loan, contributions or anything else of value from any organization or individual if it could be reasonably construed or perceived that the gift is motivated by a wish to influence TI Georgia.

Low value gifts may be accepted (e.g. diaries, calendars, books, publications, souvenirs, etc.). Supervisor must be immediately informed if such occurs.

     5. Reporting allegations of fraud and corruption

Concerns must be raised when staff members or anyone associated with TI Georgia reasonably believe that one or more of the following has occurred, is in the process of occurring, or is likely to occur:

  • A failure to comply with the present policy
  • Improper or unauthorized use of funds
  • Intentional concealment of or complicity in any of the above.

All concerns/allegations must be raised with the Chair of the Board, Executive Director or a member of the Senior Staff. Concerns/allegations on the Executive Director, should be directed to the Chair of the Board. Allegations received by anonymous letters or phone calls will be taken into consideration and investigated in appropriate manner. In such cases the procedure must be initiated by the administrative manager and financial manager, the Chair of the Board and the Executive Director must be notified. Any reported allegations of such conduct shall be recorded in detail as soon as possible by the person who received the complaint.

     6. Investigation

Any instances of actual or potential fraudulent conduct/corruption shall be properly and promptly investigated. The objectives of an investigation shall be:

  • Confirm whether or not a fraudulent action/act of corruption/extortion/facilitation payments/acceptance or giving inappropriate gift/hospitality has taken place, and to identify who was responsible.
  • Determine the appropriate subsequent action, depending on the findings of the investigation. This may include disciplinary procedures and/or external reporting to the competent authorities.

     7. Committee of Ethics

Each allegation of inadequate conduct shall be investigated by an ad hoc Committee of Ethics.

The composition of the Committee of Ethics is determined by the Executive Director together with the Chair of the Board, in case of incompatibility the decision on the formation of the Committee shall be taken exclusively by the Board. The Committee shall be composed of a minimum of 3 persons. Any decision should be taken by an absolute majority. Composition of the committee is decided by the Board of TI Georgia.

Committee could be staffed by TI Georgia staff or outside (non-affiliated) persons.

All the deliberations and findings of the Committee should be recorded and signed by each member.

     8. Training and awareness

Each Project Manager shall inform the employees under his/her supervision about this policy and procedures.

The Chair of the Board and Executive Director is responsible for ensuring that all persons who are associated with the activities of TI Georgia are made aware of this policy and procedures provided by it.

Depending on the responsibilities and the related risks all relevant employee may undergo special training on the potential risks of fraud/corruption, how such actions might affect them, what they should do if they are offered a bribe, and the consequences of making or accepting bribes.

     9. Whistleblowing

Employees, ex-employees, Board members, Interns, volunteers, representatives of the organization, contractors, or any other person outside the organization are able to report their concerns/allegations about unethical or illegal conduct committed by an employee or a Board member of the organization by using the email

Concerns/allegations on the Executive Director should be reported through the email All employees and Board members have a duty to report fraud and offences of an administrative or criminal nature.

All concerns and allegations shall be investigated by the Committee of Ethics.

     10. Confidentiality

All concerns and allegations will be treated in confidence and every effort will be made not to reveal the identity of the whistleblower. However, in order to investigate the matter properly, the Committee of Ethics may need to ask for files or question other employees, so it is impossible to guarantee complete confidentiality.

It may be necessary to reveal the identity of the individuals in cases which are clearly serious that police, or other relevant law-enforcements may have to be involved.

The whistleblower’s identity may be disclosed if he or she agrees or unless there are grounds to believe that they have acted maliciously.

     11. Allegations in bad faith

Allegations made by the employees in bad faith may result in disciplinary action.