ICARS anti-bribery, fraud and corruption policy

Approved by the Board of Directors in 2024 and 2026. The latest review was done in April 2026.

Introduction

ICARS is determined to maintain the highest standards of integrity and work ethics among staff across all areas of activity, as well as ensuring the proper administration of funds. For this reason, ICARS maintains a policy of zero tolerance for bribery, fraud and corruption in all its forms, meaning that persons covered by ICARS Code of Ethics & Professional Conduct and this complementary policy are not allowed to engage in bribery, fraud or corruption.

ICARS relies on common definitions of bribery as offering, promising, giving, accepting, or soliciting an advantage as an inducement for an action that is illegal, unethical, a breach of trust or provides unfair advantage; of fraud as the use of deception by an individual with the intention of obtaining an unfair advantage for this person or for others and thereby inducing another person or party to an act or omission causing loss to this other individual, party or another affected party; and of corruption as the abuse of entrusted power for one’s own benefit.

This policy addresses the awareness, prevention, identification, reporting, investigation and consequences of bribery, fraud and corruption at ICARS.

The Policy is not intended to describe all examples of fraudulent, corrupt, or otherwise prohibited conduct, and should be read in conjunction with ICARS Code of Ethics & Professional Conduct as well as other applicable policies, such as the Conflict of Interest Policy, the Risk Management Policy, and the Whistleblowing Policy.

Where donor regulations are more restrictive than this policy, those regulations must be complied with and incorporated in ICARS work.

ICARS’ policy is that:

• Any level of bribery, fraud, or corruption in or against ICARS will not be tolerated;
• Every attempt will be made to deter and prevent bribery, fraud and corruption;
• Opportunities for bribery, fraud and corruption will be reduced to the lowest possible level of risk;
• Staff and partners will be made aware of the obligation to report suspicions of bribery, fraud and corruption.

Purpose

The aim of this Policy is to safeguard the reputation and financial viability of ICARS through consistent management and prevention of bribery, fraud and corruption risk.

Coverage and scope

In accordance with the ICARS Code of Ethics & Professional Conduct, this Policy applies to the following (all “Covered Persons”)

(a) Members of ICARS’ Board of Directors and other governing bodies such as advisory forums
(b) ICARS Staff
(c) ICARS Partners: ICARS requires that third parties, who work with or on behalf of ICARS, i.e., grant recipients, service providers, and consultants (collectively, “Partners”) will meet the standards embodied in this policy.

This Policy applies to all internal and external activities and operations of ICARS, including i) Any project (co-)funded by ICARS; and ii) any project implemented by ICARS and any government agency and/or other cooperating partner.

ICARS measures to prevent bribery, fraud, and corruption

ICARS commits to fight bribery, fraud, and corruption by:

1. Demonstrating top-level commitment to mitigate the risk of bribery, fraud, and corruption
2. Promoting a culture of integrity, accountability, and ethics in line with the ICARS Code of Ethics and Professional Conduct
3. Conducting regular bribery, fraud, and corruption risk assessments of operations
4. Implementing procedures proportionate to the risks identified
5. Ensuring openness and transparency toward the general public and ICARS partners. In accordance with ICARS statutes, information is generally accessible to the general public in accordance with the Danish Public Administration Act and the Danish Access to Public Administrative Documents Act. ICARS further ensures openness and transparency through ICARS’ own website (www.icars-global.org) and other means, such as ICARS social media platforms.
6. Conducting adequate and proportionate due diligence on partners, grant recipients and third-party service providers ICARS’s partners are both governments of Low- and Middle-income Countries (LMIC) and other organisations/entities, such as international and local organisations, initiatives and companies. Therefore, the due diligence process conducted on downstream partners will depend on the nature of the partnership and the type of the partner entity involved. Standard Due Diligence Operating Procedures have been implemented for due diligence of partners and grant recipients prior to agreements being made.
7. For projects funded by ICARS, ICARS will be conducting regular meetings to monitor and control project implementation, with the initial meeting taking place before the start of the implementation process, where the requirements and reporting procedures are clarified and explained to the grant recipients.
8. Procurement of goods or services on behalf of ICARS must be made in accordance with the internal ICARS’s Procurement Policy or where contractual obligations dictate otherwise, with procurement rules of another party so long as they are regarded as reflecting international best practices.
9. Including the zero-tolerance policy for bribery, fraud, and corruption and appropriate clauses about the consequences of bribery, fraud and corruption in all contractual arrangements, as well as requiring the signing of a statement of compliance (which includes reference to the clauses on bribery, fraud and corruption) by all partners for disbursement of continued funds under grant agreements.
10. Awareness raising among, and training of, covered persons on the content of this policy and related policies, such as the ICARS Code of Ethics and Professional Conduct.
11. Implementing and regularly evaluating the effectiveness of bribery, fraud, and corruption prevention procedures and strengthening the procedures based on the outcome of the evaluations.
12. Effective internal and external auditing controls, the results of which will be reported directly to the Board of Directors and followed up by the Executive Management as appropriate.

Roles and responsibilities

In addition to the roles and responsibilities outlined in the ICARS Code of Ethics & Professional Conduct, each individual covered by this policy and ICARS senior staff and management have the following responsibilities:

The Board of Directors

• Assign a member of the ICARS Board of Directors to be responsible for overseeing the organisation’s work to prevent anti-bribery, fraud and corruption in its activities. This board member acts as a champion for the Anti-bribery, fraud, and corruption policy, is a point of contact for ICARS management to discuss policy issues and provides oversight on the implementation of the policy.

ICARS Executive Management and Heads of Teams

• Ensure that reasonable steps are taken to prevent bribery, fraud and corruption of ICARS’ funds and that proper, transparent, robust financial controls and procedures suitable for ICARS’ activity are in place.
• Keep proper and adequate business and financial records for both the receipt and use of all funds together with audit trails of decisions made.
• Authorize, review and monitor the implementation of this Policy.
• Ensure adequate resources are allocated to tackle the risk of bribery, fraud and corruption.
• Ensure that bribery, fraud and corruption risks are regularly assessed and included in strategic risk management.
• Ensure that proportionate and adequate measures to mitigate risks are applied – at the organizational and at project level (view the ICARS Risk Management Policy).
• Act responsibly within the interests of ICARS and in line with the principles of response set out in this Policy if a suspicion occurs.
• Sensitize staff and partners about the bribery, fraud, and corruption risks in the local environment regularly, act transparently, and encourage open discussion on challenges.
• Ensure implementation and communication of a management action plan after a reported incident.
• Take prompt action to seek restitution from the individual(s) or entities responsible where ICARS has suffered monetary loss or loss of other material assets.
• Review the implementation of the changes made to the system of internal control subsequent to a case of bribery, fraud or corruption to evaluate their efficiency and effectiveness.

The individual

• Must not engage in any form of bribery, fraud, or corruption, either directly or through any third party, including offering facilitation payments (also termed small bribes) on ICARS’s behalf or in connection with any contract entered into with ICARS.
  • This includes where the offer or receipt is intended for example for an individual’s relatives or colleagues, or when bribery, fraud, or corruption takes place through third parties. Facilitation payments are unofficial (often relatively small) payments made with the purpose of expediting or facilitating the performance by a public official of a routine government action to which the payer is legally entitled.
• ICARS recognizes that covered persons may be faced with situations where health and security are seriously at risk and where a facilitation payment is unavoidable. In such cases payment can be made, keeping it to the minimum possible level. However, this only applies in exceptional circumstances when individuals are left with no alternative but to make the payment because of an imminent threat to health, safety, or liberty (duress payments, which provide a legal defence for the payment in most jurisdictions). The person shall report the amount and circumstances to the Executive Management or the Safeguarding Officer and the incident may be reported to relevant local law enforcement authorities.

• Gifts[4], hospitality and gratuities

In the context of bribery, fraud, and corruption, a gift is a financial or other benefit, offered, given, solicited, or received in the expectation of receiving a benefit in return. Gifts and hospitality (e.g. meals, hotels, flights, entertainment, or sporting events) may be in themselves a manifestation of corrupt behaviour.

Gifts, hospitality and other benefits may not be given on behalf of ICARS or received by ICARS staff to or from project partners, public officials or service providers unless they:

1. are acts of courtesy and of modest value.
2. do not compromise the integrity and/or the reputation of any of the parties; and
3. do not create the appearance of impropriety.

Permissible gifts and hospitality should also have all the following characteristics:

• not be a cash payment.
• be provided in connection with bona fide and legitimate business purposes.
• not be motivated by the desire to exercise improper influence or the expectation of reciprocity.
• be reasonable according to the circumstances.
• be commensurate with generally accepted standards of professional courtesy, and
• comply with local laws and regulations applicable to public officials or service providers.

Further, all gifts given to third parties must be in accordance with the ICARS gift policy.

ICARS acknowledges that the practice of giving business gifts and hospitality varies between countries and regions, and what may be normal and acceptable in one region may not be in another. There may thus be exceptional cases when gifts or hospitality above the limits defined previously in this policy are not appropriate to decline. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered. Any cases, when gifts may potentially conflict with this policy, shall be reported to the ICARS Executive Management and the Safeguarding Officer for consideration and decision.

Furthermore, the individual

• Must report any suspected or confirmed incidents of bribery, fraud and corruption involving ICARS funds as required by this policy and the partner/ grant agreement, and using the reporting channels as outlined in the ICARS Code of Ethics and Professional Conduct (section 6.7: Reporting unethical misconduct) and the Whistleblowing Policy;

• Must respond to bribery, fraud and corruption incidences observed or reported to them pursuant to the principles set out in this Policy and following the process as outlined in the ICARS Code of Ethics and Professional Conduct (sections 7: complaints or concerns procedure, and 8: Responses to code violations and follow-up) and the Whistleblowing Policy.

To help identify cases of bribery, fraud and corruption, some examples have been set out in APPENDIX 1, however, this list is not exhaustive. If in doubt, contact ICARS Executive Management, the Safeguarding Officer (ethics@icars-global.org), or report any suspicions via the ICARS whistleblowing system.

Monitoring and Review

Aggregated data on Bribery, Fraud and Corruption incidents and risks thereof will be reported on an annual basis to the Board of Directors.

The Board of Directors shall authorize and oversee a periodic review of the administration of this policy at least every two years or as required by legislation or experience. The review may be written or oral. The review shall consider the level of compliance, the continuing suitability, and whether the policy should be modified and improved.

Any changes to the policy shall be communicated immediately to all Covered Persons.

Appendix 1 – Examples of bribery, fraud, and corruption

• An ICARS staff member needs to pass a border checkpoint; by paying $25 to the officials there is a “fast track” process (facilitation payment, i.e. a “small” bribe).
• Charging ICARS for goods and services that have not been delivered.
• Seeking to obtain confidential information about a colleague or others, with intent to use it for unauthorized purposes.
• Knowingly providing false, misleading, or incomplete information to ICARS, donors, partners, or other business relations, or deliberately failing to provide information where there is an obligation to do so.
• To speed up the process of co-development or implementation of a project in a partner country a gift is provided by ICARS to the partner organisation (or an inference may be drawn to this effect).
• ICARS decides to go with one ministry instead of another as a project partner, because of a gift received (or an inference may be drawn to this effect).
• ICARS decides to provide more support in project implementation to a specific government partner because of a gift received (or an inference may be drawn to this effect).
• Accepting payment to a public official for expediting clearing customs at the airport (facilitation payment, i.e. a small bribe).