Governance: Anti-Corruption and Anti-Fraud Policy

  1. Preamble
  2. Rationale
  3. Prevention
  4. Reporting (Whistle Blowing)
  5. Response to accusations of fraud
  6. Policy Review

1. Preamble: Palms Australia is anti-fraud and anti-corruption.

Palms Australia is strongly committed to principles of accountability and transparency to all stakeholders. Included in this commitment is a ‘zero-tolerance’ opposition to all forms of corruption and fraud.

Palms Australia has an obligation to members and donors to ensure that all monies used by the organisation are used for their articulated purposes and that processes are in place to ensure that fraud against the organisation is prevented and mitigated against.

Palms Australia understands that in many countries, corruption is one obstacle to economic and social justice. We seek to promote ethical behaviour in the countries where we work. All staff must take care to avoid participating in practices which promote corruption in the public, private or not-for-profit sectors in Australia or partner countries.

2. Rationale

This policy is designed to clearly articulate:

  • Palms Australia’s opposition to all forms of corruption and fraud;
  • Measures taken to prevent fraud and corruption within the organisation;
  • Processes for reporting suspicions or accusations of corruption or fraud by Palms Australia staff or representatives;

Fraud is dishonestly obtaining a benefit, or causing a loss, by deception or other means. This may include theft of funds from Palms Australia, partner agency or donor.

Corruption refers to “the misuse of entrusted power for private gain”. Commonly this includes bribery or blackmail through the withholding or providing of services in return for personal gain.

3. Prevention

Palms Australia staff should take all appropriate efforts to prevent and avoid corruption or fraud, or the appearance of such, in their work.  This includes prevention of the misuse of funds or other property of Palms Australia, including intellectual property and stakeholder information protected under the Privacy Policy.

As Palms Australia does not directly fund projects in country, and due to financial oversight by the Board of Directors and Annual Auditting and Reporting procedures, the opportunities for fraud are limited.

Palms Australia will not provide loans to staff members or directors for any purpose.  Any reimbursement of costs incurred as part of Palms’ operation must be properly accounted for through Palms Accounting Processes.

Relevant staff must abide by Administration and Finance Procedures (Accounts Processing Schedule, Cheque Requisition, Funds inwards, Petty Cash, Purchase Requisition, Travel Advances and Expense Reporting, Wages Processing), which are designed to ensure financial transactions are in line with Palms Australia’s commitment to accountability.

Board members and staff must abide by Palms Australia’s Honesty and Disclosure of Interest Policy.

Palms Australia program staff should be aware that at times corrupt individuals may seek to delay or disrupt services in an effort to acquire bribes of money or goods. This may include during applications for visas or work permits. In all instances, staff should avoid indulging such requests. If a staff member suspects a contact of corrupt behaviour, they should seek advice from the Executive Director on an appropriate course of action.

Coordinators, Managers and Directors of the organisation are expected to be familiar with the Risk Management Matrix, particularly where it is related to their primary area of work.

All new policies should be written with consideration of risks associated with the potential for financial wrongdoing or impropriety.

4. Reporting (whistle-blowing)

Any individual with suspicions of corruption or fraud by a member of Palms Australia’s staff or board, should immediately raise their concerns with the Executive Director or President of the Board. Such contact shall be handled confidentially and the “whistle-blower” will be contacted immediately so that the concerns may be properly understood and contextualised. The “whistle-blower” shall not be identified to the accused staff member during the investigation without their consent.

5. Response to accusations of fraud

The Executive Director or Board of Directors will investigate the truth of any accusation immediately, taking steps where appropriate to prevent future or ongoing fraud, or cover-up of misdoings.

Where a member of the Board or staff of Palms Australia has been accused of fraud, Palms Australia may take legal action to recover all losses, including legal fees. If appropriate a case may be referred to law enforcement agencies. Such action will be at the discretion of the Board of Directors.

6. Policy Review

This policy will be reviewed at least every three years. The most recent review was conducted in December 2012.

There is much more to doing good work than "making a difference." There is the principle of first do no harm.
There is the idea that those who are being helped ought to be consulted over the matters that concern them. - Teju Cole