Anti-Corruption and Integrity Safeguards Policy

(Anti-Corruption and Integrity Safeguards Policy)

WOMEN AND CHILD RESILIENCE FOUNDATION (WCR INDONESIA)

I. INTRODUCTION

WCR Indonesia is committed to conducting all organizational activities professionally, transparently, accountably, independently, and with high integrity. In carrying out the vision and mission of the organization, WCR Indonesia strictly prohibits any form of corruption, bribery, gratuities, embezzlement, abuse of authority, conflict of interest, money laundering, illegal funding, or other unethical practices.

This Anti-Corruption and Integrity Policy is part of the organization’s safeguards to ensure that all program, operational, financial, procurement, partnership, and governance activities are conducted in accordance with good governance principles, Indonesian law, and international organizational ethics standards.

This policy serves as a mandatory guideline for all organizational bodies and all parties collaborating with WCR Indonesia.

II. LEGAL BASIS

This policy is guided by Indonesian laws and regulations and principles of good organizational governance, including:

1. 1945 Constitution of the Republic of Indonesia
2. Criminal Code (KUHP)
3. Law No. 28 of 1999 and amendments regarding Clean and Corruption-Free Governance, including Law No. 30 of 2002 and Law No. 19 of 2019
4. Law No. 31 of 1999 and amendments concerning Corruption Eradication
5. Law No. 16 of 2001 regarding Foundations and its amendments
6. Law No. 8 of 2010 on the prevention and eradication of money laundering
7. Law No. 13 of 2006 and amendments on Witness and Victim Protection
8. Corruption Eradication Commission (KPK) and relevant anti-corruption guidelines
9. Articles of Association and Bylaws (AD/ART) of WCR Indonesia
10. Code of Ethics, internal policies, and good governance, transparency, accountability, and safeguarding principles

III. OBJECTIVES

The policy aims to:

1. Prevent corruption, fraud, and abuse of authority within the organization
2. Establish standards of integrity and professional conduct
3. Ensure lawful, effective, efficient, and accountable use of organizational funds and assets
4. Enhance transparency and accountability across all processes
5. Protect the organization’s reputation, credibility, and sustainability
6. Build trust with donors, partners, beneficiaries, government, and the public
7. Ensure compliance with applicable laws, regulations, and governance standards

IV. SCOPE

This policy applies to:

• Board of Trustees, Supervisors, and Management
• Directors, management, and all staff
• Permanent employees, contractors, interns, and volunteers
• Consultants, experts, facilitators, and resource persons
• Vendors, contractors, and service providers
• Program partners and other third parties
• All parties using, managing, or receiving organizational funds and facilities

The policy covers all organizational activities, including:

• Financial management
• Procurement of goods and services
• Human resources recruitment and development
• Program implementation
• Asset management
• Partnerships and collaboration
• Grant, aid, or sponsorship distribution
• Relations with government or external parties

V. DEFINITIONS

1. Corruption: Any illegal act involving misuse of position, authority, opportunity, or resources for personal, group, or other party gain, detrimental to the organization or public interest.
2. Bribery: Giving, offering, receiving, or requesting something of value to influence decisions, actions, or policies.
3. Gratuities: Giving money, goods, discounts, commissions, loans, travel tickets, facilities, gifts, or other forms related to position or authority.
4. Conflict of Interest: Situations where personal, family, relational, political, or business interests influence or potentially influence objectivity and independence in performing organizational duties.
5. Fraud: Acts of deception, manipulation, falsification, omission of information, or misuse of assets for unauthorized gain.
6. Asset Misuse: Using organizational funds, facilities, equipment, vehicles, data, or resources for personal purposes or outside organizational interests.

VI. PRINCIPLES

WCR Indonesia applies the following principles:

1. Integrity
2. Transparency
3. Accountability
4. Independence
5. Professionalism
6. Compliance with laws
7. Zero tolerance for corruption and fraud
8. Whistleblower protection

VII. POLICIES AND PROHIBITIONS

1. Giving, offering, promising, requesting, or receiving bribes
2. Misusing organizational funds
3. Mark-ups, budget manipulation, cost inflation, or document falsification
4. Using personal accounts for organizational funds without approval
5. Using organizational assets for personal purposes
6. Accepting gifts that may affect independence and objectivity
7. Nepotism, collusion, or favoritism in recruitment, procurement, and decision-making
8. Splitting transactions to avoid approval procedures
9. Destroying, hiding, or falsifying financial records
10. Obstructing audits or investigations

VIII. CONFLICT OF INTEREST MANAGEMENT

1. Disclose any potential conflicts in writing
2. Individuals with conflicts must abstain from relevant decisions
3. Sign Conflict of Interest Statements periodically
4. Organization may perform independent checks on potential conflicts

IX. INTERNAL CONTROL AND PREVENTION SYSTEM

1. Financial Management

• Transparent bookkeeping and record-keeping
• Multi-level authorization
• Segregation of finance, verification, and approval duties
• Periodic financial reconciliation
• Internal and independent external audits

2. Procurement

• Transparent and documented procurement process
• Objective and competitive vendor selection
• No conflicts of interest in procurement
• Due diligence for vendors and partners

3. Human Resources

• Competency-based recruitment
• Signing code of ethics and integrity pact
• Regular training on anti-corruption and organizational integrity

4. Program Management

• Periodic program monitoring and evaluation
• Verification of program fund usage
• Accurate documentation and reporting

X. REPORTING MECHANISM

Safe, confidential, and accessible reporting via:

• Official organization email
• Hotline or complaint channels
• Written letters
• Anonymous reporting channels

Reports may include allegations of:

• Corruption
• Fraud
• Misuse of funds
• Conflict of interest
• Code of ethics violations
• Abuse of authority

XI. HANDLING AND INVESTIGATION

Protection for good-faith whistleblowers against:

• Intimidation
• Threats
• Discrimination
• Unlawful termination
• Retaliation

Whistleblower identity is kept confidential.

XII. SANCTIONS

1. Receipt of report
2. Initial verification
3. Risk assessment
4. Internal or independent investigation
5. Investigation report preparation
6. Decision and recommendation issuance
7. Follow-up and recovery of losses

Alleged criminal acts may be reported to law enforcement.

XIII. ROLES AND RESPONSIBILITIES

1. Board of Trustees, Supervisors, and Management
   • Set organizational integrity policies
   • Ensure effective implementation
   • Provide integrity example
2. Management
   • Implement internal control system
   • Follow-up audit reports and recommendations
   • Ensure unit compliance
3. Staff and Personnel
   • Comply with policy and code of ethics
   • Maintain integrity in duties
   • Report suspected violations
4. Partners and Vendors
   • Comply with organizational integrity standards
   • Allow audits if necessary
   • Refrain from corrupt practices

XIV. MONITORING, AUDIT, AND EVALUATION

1. Policy evaluated at least every 2 years
2. Internal and external compliance audits
3. Evaluation results inform organizational safeguard improvements
4. All units support open monitoring and audit processes

XV. CLOSING PROVISIONS

The policy is effective from the date established and must be complied with by all parties.

WCR Indonesia enforces zero tolerance for corruption and integrity violations.

Established in Jakarta
Date: 20 July 2023

Dr. Margaretha Hanita, S.H, M.Si.
Chairperson of Women and Child Resilience Foundation