ICARS code of ethics & professional conduct

Approved by the Board of Directors on 28 January 2022

1. Introduction

For ICARS to achieve its mission, ICARS must adhere to its five core principles (country ownership, one health, partnership, solution-focused and sustainability), and furthermore, ICARS employees and partners must unconditionally be guided by fundamental values such as integrity, respect, transparency, and accountability.

The responsibility to behave in a manner that supports the achievement of ICARS’ mission, and enhances ICARS reputation, lies with all those associated with ICARS and its work. Any intentionally inappropriate, especially unethical, or even criminal, behavior is unacceptable and has the potential to cause harm, and tarnish ICARS’ work and reputation and thereby its mission.

This Code of Ethics & Professional Conduct (hereinafter referred to as the “Code”) describes the ethics and behaviors expected of all people associated with ICARS. It is designed to create a culture of best practice, which all partners should also adhere to. Therefore, this Code forms part of ICARS’ grant terms and conditions.

This Code includes the guiding principles and key ethical values that shall guide ICARS’ work. It is designed to familiarize all Covered Persons (as defined in section 3) and other interested people with ICARS policy positions on several issues. The Code is complemented by a suite of ICARS policies on specific ethics-related topics, such as conflict of interest, as well as policies for specific groups, such as the Code of Conduct for members of the Board of Directors, to address the unique roles, ethical risks and opportunities that arise from their conduct. Where already available, these policies are referred to in the relevant section of this Code. Further, all up to date polices can be found on the following ICARS webpage:  ICARS’ policies – ICARS (icars-global.org). Policies describe behavioural expectations, resources for help and guidance, responsibilities, and reporting systems to address misconduct and unethical behaviour.

While the Code provides a broad range of guidance about the standards of ethical conduct, it does not (and cannot) address every situation that Covered Persons are likely to encounter. In such cases, the Covered Person is encouraged to seek guidance from ICARS Director of Operations and/or the Safeguarding Officer (ethics@icars-global.org).

2. Purpose

The purpose of this Code is to strengthen the ethical foundation of ICARS and thereby to ensure a robust safeguarding environment.

3. Coverage

This Code 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, consultants (collectively, “Partners”) will meet the standards embodied in this policy.

4. ICARS core ethical values

ICARS has identified the following fundamental values to guide Covered Persons.

1.1.   Integrity

Being honest and showing a consistent and uncompromising adherence to strong moral and ethical principles and values.

1.2.   Transparency

Protecting and promoting the free flow of accurate and complete information regarding ICARS activities and (co-) funded projects and related actions by embracing open communication and timely sharing of information within ICARS, and with ICARS’ partners, funders, and other interested stakeholders, subject to relevant obligations of confidentiality and data privacy protection.

1.3.   Respect (for the dignity, worth, equality, diversity and privacy of all persons)

Embracing diversity and inclusion, treating all stakeholders with respect and dignity, promoting equity, equality and diversity, avoiding all forms of discrimination, protecting privacy and promoting human rights.

1.4.   Accountability

Taking responsibility for one’s actions, decisions and their consequences.

5. Roles and Responsibilities

5.1.   The individual

It is the responsibility of each Covered Person to:

  • understand and comply with the Code and complementary policies and procedures;
  • be aware of developments around them and promptly and appropriately raise concerns;
  • seek guidance if unsure whether or not a decision or action that is being considered/ conducted is in accordance with the law, the Code, or complementary policies; and
  • refrain from all forms of retaliation against another person for raising an integrity concern and cooperate fully and honestly in any investigations.

5.2.   ICARS senior staff and management responsibilities

Senior staff and the Executive Management should lead by example and are expected to:

  • know, understand and comply with this Code and complementary policies, including to provide guidance to and advise staff on their rights, responsibilities and obligations;
  • exemplify and reinforce behaviors that reflect ICARS values;
  • create an organizational culture and team environment where issues can be discussed and where staff feel comfortable with raising concerns;
  • establish, and monitor implementation of, formal procedures to address violations of this Code
  • ensure that communicated concerns receive proper attention, response, documentation, and are managed as described in this Code;
  • support staff members who raise an ethical concern;
  • train all existing ICARS staff of the content of this Code and complementary policies and procedures, and all new ICARS staff during induction/orientation sessions;
  • develop and/or monitor mechanisms for ensuring that all ICARS partners are informed of this Code, complementary policies and their obligations; and
  • undertake training courses to develop management skills related to this Code.

 6. ICARS organizational commitments/ policy statements

6.1.   Legal Compliance

ICARS complies with the legislation and regulations of Denmark, local laws and regulations in countries where ICARS operates through project-work and travel, as well as applicable international law. ICARS also requires its staff and partners to abide by local laws and by applicable international instruments, including e.g., the UN Convention on the Rights of the Child and International Labour Organisation conventions. ICARS staff meets all contractual obligations towards third parties and observes any voluntary commitments and policies of ICARS.

ICARS Grant Agreement Terms and Conditions
Section 4 on legal compliance is an integral part of ICARS Grant Agreement terms and conditions.

All disbursements of [ICARS] funds are subject to the receipt of a statement of compliance (annex 5) (section 4.5).

The failure to comply with section 4 constitutes a material breach, and therefore reason for termination of each grant agreement.

6.2.   Bribery, fraud, corruption

ICARS has zero tolerance for bribery, fraud and corruption in all forms, meaning that there are no acceptable excuses for Covered Persons to engage in bribery, fraud or corruption.

All incidents of suspected bribery, fraud and corruption are to be reported to ICARS and will be treated seriously and in accordance with this Code and ICARS bribery, fraud and corruption policy.

ICARS defines 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; fraud as the use of deception by an individual with the intention of obtaining an advantage for himself or herself or for another third party or parties, avoiding an obligation, or causing loss to another party; and corruption as the abuse of entrusted power.

ICARS Grant Agreement Terms and Conditions
Section 9/10 on bribery, fraud and corruption is an integral part of ICARS Grant Agreement terms and conditions:

The Parties have zero tolerance for bribery, fraud and corruption in all forms.

No offer, gift or payment, consideration or benefit of any kind, which could be regarded as an illegal or corrupt practice, shall be made, promised, sought or accepted – neither directly nor indirectly – as an inducement or reward in relation to activities funded under this agreement, incl. tendering, award, or execution of contracts. Any such practise will be grounds for the immediate cancellation of this funding and for such additional action, civil and/or criminal, as may be appropriate. All incidents of suspected bribery, fraud and corruption shall be reported to ICARS.”

To ensure compliance and generally raise awareness, all disbursements of funds are subject to the receipt of a statement of compliance, which also includes reference to section 9/10 (section 4.5).

The failure to comply with section 9/10 constitutes a material breach, and therefore a reason for termination of each grant agreement.

6.3.   Conflicts of interest

ICARS is committed to conducting all its activities, including in governing bodies, advisory forums and when partnering with other organisations and research institutions, in a manner that ensures that ICARS’ activities and decisions are taken in the best interest of ICARS and are not influenced by undue personal interests. Conflict of interests arise when personal, social, financial or political interests may be placed before those of ICARS or the people and partners it seeks to serve or work with, or when they may be perceived as doing so.

Examples of situations to be avoided
It is difficult to address every situation in which a conflict of interest may arise, but below are two indicative examples of conflictual situations:

·          Accepting gifts or entertainment (hospitality) other than of minimal value[1], or anything else of monetary value which could be interpreted as intending to improperly influence a decision or which could unduly affect professional judgment or otherwise raise concerns about ICARS’ integrity and/or an ICARS supported project.

·          Taking advantage of or seeking to obtain personal gain from any opportunity learned of while doing any work for ICARS or an ICARS supported project that could have benefitted ICARS or the project.

ICARS has adopted a more comprehensive Conflicts of Interest Policy that is available on its website. The Policy is designed to help identify situations that present actual, perceived or potential conflicts of interest and to provide clear, transparent, and effective procedures on how to avoid or manage such situations. It also includes templates to disclose any circumstances that could give rise to an actual, perceived or potential conflict of interest.

ICARS Grant Agreement Terms and Conditions
Section 12/13 on conflict of interest is an integral part of ICARS Grant Agreement terms and conditions:

“The grant recipient will ensure that it has adequate procedures in place to enable early identification and effective management of any actual, potential or perceived conflicts of interest which it or its Staff may have in relation to this Grant Agreement. Where the grant recipient identifies any actual, potential or perceived conflict of interest it will notify ICARS of this and provide information about how this is being managed in accordance with the ICARS conflict of interest policy.”

To ensure compliance and generally raise awareness, all disbursements of funds are subject to the receipt of a statement of compliance, which also includes reference to section 12/13 (section 4.5).

The failure to comply with section 21/19 constitutes a material breach, and therefore a reason for termination of each grant agreement.

6.4.   Safeguarding 

Safeguarding is an all-encompassing term, which is broadly defined as “a framework to protect from harm, damage or exploitation with appropriate measure”. It can be applied to multiple concerns, such as for example discrimination, bullying, harassment, or the environment.

ICARS respects the rights of all people, and all Covered Persons have a duty of care toward others as well as toward the environment.

Diversity, equality, equity, and respect

ICARS has a zero-tolerance policy towards any kind of discrimination. Rather ICARS values, respects and strives to increase diversity, equity and inclusion to the greatest extent possible.

ICARS actively promotes gender equality, at the workplace as well as generally in the implementation of projects and related activities.

Examples of activities to actively promote diversity and gender equality
According to ICARS Statutes, gender balance must be ensured when appointing voting members of the Board of Directors (Article 6.11)

We practice the following commitments in our recruitment:

“We are committed to cultivating a fair and healthy environment, where everyone can be themselves and thrive. We are happy to discuss flexible working options for all roles. We work to ensure that our recruitment processes are as inclusive as possible to everyone. This includes making adjustments for people who have a disability or long-term condition.”

Section 4.7 is an integral part of our ICARS Grant Agreement terms and conditions:

“The grant recipient must take all measures to promote equal opportunities between men and women in the implementation of the project. They must aim, to the extent possible, for a gender balance at all levels of personnel assigned to the project, including at supervisory and managerial level.”

Project activities, such as for example, the joint ICARS/ International Development Research Centre (IDRC) project on “Strengthening gender equality and social inclusion in LMICs across the AMR intervention and implementation research continuum”, initiated in the fall of 2021. The project aims to identify priority research gaps and develop practical evidence-based guidance to help governments and researchers in and working with LMICs adopt more progressive gender lenses into AMR intervention and implementation research projects in human and animal health.

Prevention of sexual exploitation, abuse and harassment and Protection of vulnerable people

ICARS has a zero-tolerance policy towards abuse, exploitation and harassment, whether sexual or otherwise, as well as bullying perpetrated by Covered Persons. While this applies for all persons, ICARS is sensitive that it is of particular importance in the case of vulnerable groups in low- and middle-income countries (LMICs) as well as elsewhere (i.e., children, women and vulnerable adults, specifically those who are unable to take care of or protect themselves).

All sexual activity involving children in any manner (persons under the age of 18) is prohibited, regardless of the age of majority, or age of consent locally[2].

ICARS defines sexual abuse as actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions; sexual exploitation as any actual or attempted abuse of position of vulnerability, differential power or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another; sexual harassment as any form of unwanted verbal, non-verbal or physical conduct of a sexual nature with the purpose or effect of violating the dignity of a person, in particular when creating an intimidating, hostile, degrading, humiliating or offensive environment; and bullying as intentionally and repeatedly inflicting injury or discomfort upon another person, through physical contact, through words, or in other ways and which involves a real or perceived power imbalance.

ICARS will seriously address any suspected or reported episode of abuse, exploitation, harassment or bullying through careful examination of allegations and investigation, reporting/ documentation, implementing appropriate actions to address the situation and prevent recurrence, learning (e.g., revision of policies and practices post episode and training) and providing support to those affected/ the survivors.

Key implementation measures
Training on safeguarding: ICARS commits to ensuring all Staff are trained on safeguarding and encourages its Partners to ensure that they do the same. Online training on safeguarding is available, for instance, at https://agora.unicef.org/course/info.php?id=7380. Depending on the nature of each ICARS (co)-funded project specific requirements for training of project staff (from ICARS and the respective partner) will be agreed upon in each individual case. To facilitate the identification of the appropriate training a training guidance sheet will be developed.

ICARS grant terms and conditions: Section 11/12 of ICARS grant terms and conditions on Prevention of sexual exploitation, abuse and harassment is an integral part of ICARS grant terms and conditions. The grant recipient is in particular required to immediately contact ICARS, to report any credible suspicions of, or actual incidents of sexual exploitation, abuse or harassment related to this Agreement. The grant recipient should also report any credible suspicions of, or actual incidents that are not directly related to this Agreement but would be of significant impact to their partnership with ICARS or the reputation of ICARS. For example, events that affect the governance or culture of the Partner, such as those related to senior management, must be reported.

To ensure compliance and generally raise awareness, all disbursements of funds are subject to the receipt of a statement of compliance (annex 5), which also includes reference to section 11/12.

The failure to comply with section 11/12 constitutes a material breach, and therefore a reason for termination of each grant agreement, according to the general terms and conditions.

Occupational Health & safety

ICARS is committed to provide a safe, trusted and positive working environment for its staff and nurture an organizational culture that accepts its accountability for the safety and well-being of others, and in particular vulnerable groups.

ICARS partners are required to operate with the necessary local permits, approvals and controls that are designed to protect safety and security as well as ethical conduct.

Environmental protection

ICARS is committed to avoid and/ or minimize adverse impact on the environment to the greatest possible extent and expects the same from its partners.  This is relevant both with ICARS operations, for example within the office and when making travel arrangements, as well as within project implementation where research could have a negative environmental impact. In accordance with the One-Health approach, projects that enhance environmental health are considered as well.

Examples of activities to promote environmental protection
ICARS operations

Printing: Each printing in the office requires the registration of the user at the printing machine and orders are only stored for 24 hours, thereby reducing the amount of paper printed (no paper is left behind at the printer and the user can easily correct or delete an order after having pushed the print button). Another measure to limit paper and ink is that as a default, documents are printed in black and white and two-sided.

Kitchen: No use of single-use plastic.

Travelling: Reduction of environmental impact through the choice of travel mode (preference of or encouragement to use trains where feasible), the organisation of online meetings to avoid travelling, and offsetting carbon emissions (see the ICARS travel policy).

ICARS projects

To avoid or reduce any potential impact of a project already at the design stage, an environmental guidance note/ checklist will be developed to support the project development phase and support the identification of potential safeguard mechanisms.

Project review will include an environmental screening in case safeguard risks are triggered according to a checklist (in development).

ICARS grant terms and conditions include that project with a potential to have a significant negative impact on the environment are required to undergo an environmental impact assessment in accordance with national laws and regulations (Legal compliance, section 4.2).

6.5.   Data protection

ICARS is committed to safeguarding and protecting Personal Data of private individuals. ICARS is aware of the risks involved and of the importance of having appropriate data protection standards in place. Please view the ICARS data protection policy for further information.

Personal data and GDPR compliance in the ICARS Grant Agreement
Section 15/16 on Personal data is an integral part of the ICARS Grant Agreement terms and conditions:

“15/16.1 Each Party is responsible as data controller for its processing of information relating to an identified or identifiable natural person under this Grant Agreement in compliance with applicable international and national law on data protection. In the event a Party becomes data processer the Parties enters a separate data processor agreement.

15/16.2 The Grant Recipient acknowledges that ICARS is subject to the Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and Danish data protection law..

6.6.   Responsible Research

All recipients of ICARS grants must comply with generally recognized standards for good research practice. As a minimum, this includes the rules of the research institution in question as well as all relevant laws and regulations in the country in which the grant is utilized. This includes obtaining necessary permits/ ethical approvals from research councils etc. Information on respective requirements and compliance is already requested at the project application stage through the ICARS project proposal templates.

The same standards will also apply to ICARS staff members and consultants in their role as scientific advisors, i.e., when providing technical assistance to joint research projects.

ICARS is further committed to developing a process for an ethics review of projects. This will likely include the development of an ethics self-assessment of project applicants as well as an ethical issues table against which each project will be evaluated against. Ethical issues will also be assessed in terms of identifying ethics requirements to be reported during project implementation.

ICARS Grant Agreement Terms and Conditions
Section 4 on legal compliance of the ICARS grants agreements terms and conditions is an integral part of ICARS Grant Agreement terms and conditions. This includes compliance with ethical guidelines, standards and principles, including with regard to research practice.

All disbursements of [ICARS] funds are subject to the receipt of a statement of compliance (section 4.5).

The failure to comply with section 4 constitutes a material breach, and therefore reason for termination of the agreement.

6.7.   Reporting unethical misconduct

ICARS supports a culture where ALL PEOPLE (staff members, partner employees, government officials, third parties, etc.) are empowered to speak up and challenge unethical or illegal practices, including all safeguarding breaches, that they suspect or observe.

ICARS staff or other personnel shall report a complaint or concern regarding suspected misconduct/wrongdoing of covered persons to senior staff, or the Safeguarding officer (or, depending on the issue, the Data Protection Officer), or, if the issue relates to the Executive Management, directly to the Board of Directors/ the Board member in charge of overseeing the ICARS whistleblowing system, either in person or via email. Alternatively, the issue can be reported via ICARS digital whistleblowing system in accordance with the ICARS whistleblowing policy.

ICARS partners shall report a complaint or concern regarding suspected misconduct/ wrongdoing of a covered persons to the contact person identified in the partnership agreement or the Safeguarding Officer or via ICARS digital whistleblowing system.

If a grant recipient or researcher who contributes to an ICARS supported project is found guilty of scientific misconduct, or other misconduct that impacts project implementation or potentially the reputations of ICARS and ICARS funders, the grant recipient and the host institution must inform ICARS as soon as possible after such a decision by the relevant authority.

Anybody, including partners, can report suspected misconduct by Covered Persons securely and confidentially, and if desired also anonymously, through ICARS’ whistleblower website, or through the confidential email account ethics@icars-global.org.

Protection against retaliation: Anyone who raises in good faith a concern about a possible compliance violation will be supported and protected by ICARS management and will not be subject to retaliation. Any act or threat of retaliation will be considered a serious violation of the Code. Retaliation means any direct or indirect action or omission that (1) occurs in a work-related context, (2) is the result of internal or external reporting or of public reporting, and (3) causes – or may cause – the whistleblower unjustified harm.

For more information please view ICARS whistleblowing policy.

Reporting suspected misconduct (whistle blowing)
For questions, information, or to file a complaint or report a suspected misconduct of a covered person, EVERYBODY can email the confidential account ethics@icars-global.org or report a suspected misconduct online (including with the option to report anonymously) in accordance with the ICARS whistleblowing policy.

7. Complaints or concerns procedure

Every effort will be made to deal with an issue raised in a timely manner, balancing the need to resolve issues quickly with ensuring that they are dealt with appropriately.

An initial triage system helps to identify whether issues raised qualify as whistleblowing and therefore need to be treated in accordance with the ICARS whistleblowing policy or not, but e.g., as an employee grievance, or whether they can simply be addressed via informal means. This decision is regularly undertaken by the person receiving the report, depending on the issue potentially in consultation with the Director of Operations and the Safeguarding Officer (or its representative) – while of course complying with confidentiality requirements. In any case, non-whistleblowing reports will also be treated respectfully and referred to as appropriate.

Any person against whom a concern has been raised has the right to know the nature and sufficient details of the concern in order to respond. It is important that no decision is taken until the concern has been investigated and the person against whom the concern has been raised has had the opportunity to respond. Any evidence which is entered into the official record and/or is used to make a decision must be shared with the person against whom the complaint has been raised.

Any investigation and response will always be guided by the needs and wishes of survivors (a person negatively affected by a reported illegality/ misconduct), who are treated with dignity and respect. This includes due consideration of the rights of survivors to privacy and safety. ICARS will also take account of local context to identify suitable response measures, where for example reporting to authorities would potentially cause further harm to the survivor. Consideration will also be given to the support needed by staff and partners aiding the survivor(s).

In the event that criminal behavior has been identified or suspected at any stage in this process, this procedure will be superseded, and the issue will be immediately notified to the police.

8. Responses to code violations and follow-up

Any Covered Person who violates the Code will be held accountable and may be sanctioned accordingly. This may include termination of ICARS’ relationship with a staff member or Partner.

Responses and sanctions will depend on the gravity of any determined misconduct and its implications for project implementation, the partnership, ICARS’ reputation, or the reputation of ICARS’ funders.

For further details on responses and follow-up in case of whistleblowing view the ICARS whistleblowing policy.

ICARS Grant Agreement Terms and Conditions
Any failure to comply with section 9/10 on bribery, fraud and corruption, section 10/11 on child labor, section 11/12 on prevention of sexual exploitation, abuse and harassment, section 12/13 on conflict of interest, section 13/14 on terrorism, section 8/9 on procurement and section 4 on compliance with legislation etc, as well as failure to submit declarations of compliance, explicitly constitutes a material breach of the Grant Agreement (section 21/22.2), and therefore a reason to immediately suspend ICARS obligations under the Agreement or to terminate the agreement with a 15-days’ notice period.

9. Communication and other implementation measures

The Code will be regularly communicated to all ICARS staff and other personnel and all new ICARS staff and other personnel will be provided with a copy of this Code when joining the organization. It will also be made available via the ICARS website.

In addition, ICARS must ensure that the provisions of this Code have been communicated to and are accepted by all Partners.

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

ICARS key implementation measures
  • Regular safeguarding trainings for staff, including via eLearning
  • Display of user-friendly information material, in particular on the complaint process, in the ICARS office and on the intranet
  • The appointment and training of a Safeguarding Officer, who regularly reports to the Executive Management
  • The signing of the statement of compliance by all partners for disbursement of funds under a grant agreement (section 4.5).

10. Monitoring and review

Key for the monitoring of policy implementation will be the register of safeguarding issues which shall include all issues raised and how they were dealt with.

ICARS commits to taking the lessons learnt while implementing this Code and the developments in the ethics field to improve and transform the Code and approaches to ensure success. This commitment to constant improvement will be supported by a formal assessment being performed at least every two years.

The Board of Directors shall authorize and oversee the periodic review of the administration of this policy. The review may be written or oral. The review shall consider the level of compliance with the policy, the continuing suitability of the policy, and whether the policy should be modified and improved.


[1] E.g. paying for a meal.

[2]    Based on the definition of child from the Inter-Agency Standing Committee (IASC) Guidelines to implement Minimum Operating Standards for Protection from Sexual Exploitation and Abuse by UN and non-UN Personnel, March 2013.