ERI Anti-Fraud and Corruption Policy

Revised by Board May 2023

Approved Sep 2023

  1. Introduction

ERI is committed to the highest possible standards of openness, transparency and accountability in all its affairs.  It wishes to promote a culture of honesty and opposition to fraud and corruption in all their forms.

  • Definitions

ERI defines fraud as the theft or misuse of ERI’s funds or other resources, by a member, director, officer, employee, volunteer or third party, which may or may not involve misstatement of financial documents or records to conceal the theft or misuse.

ERI defines corruption as the abuse of entrusted power for private gain by a member, director, officer, employee, volunteer or third party.

  • ERI Policy

Fraud and corruption in all their forms is wrong and is unacceptable to ERI.  This is because where fraud or corruption occur:

  • It is not just a loss to ERI, but ultimately to its beneficiaries, people living in extreme  poverty and the most needy of the world’s citizens;
  • It may have a major impact on ERI’s reputation, on donor confidence and therefore again on its beneficiaries.

ERI’s objective is that fraud and corruption are eliminated from its activities.  Any indication of fraud or corruption will be rigorously investigated and dealt with in a firm and controlled manner.

  • Responsibilities

It is the responsibility of all members, directors, officers, employees and  volunteers of ERI to be familiar with the types of fraud and corruption that might occur in their area, to be alert for any indications of fraud or corruption or improper activity and to maintain controls to avoid such occurrences.

  • Reporting Suspected Fraud or Corruption

All members, directors, officers, employees and volunteers of ERI are required to report issues of suspected fraud or corruption to the individual in ERI to whom they directly report (except that where the individual concerned is the individual to whom they directly report, they should report the issue to the Chairperson of ERI).

Members, directors, officers, employees and volunteers of ERI should not do any of the following:

  • Contact the suspected individual(s) directly in an effort to determine facts, demand explanations or restitution;
  • Discuss the issue with any person in ERI other than the individual to which they report (except where the individual concerned is the individual to whom they directly report, in which case they should discuss the issue with the Chairperson of ERI); and
  • Discuss the issue with any individual outside of ERI, except as may be required by law.

If the circumstances are such that reporting a suspicion as above is inappropriate, or if the person to whom the suspicion is unable to assist, the issue may be reported to the Chairperson of ERI.

  • Dealing with Reports of Suspected Fraud

Any reporting of a suspicion of fraud or corruption will be taken seriously by ERI.  Individuals receiving reports of a suspected fraud or corruption must immediately notify the issue to the board of directors of ERI.

  • Investigation Guidelines

In consultation with the persons notified under paragraph 5, arrangements will be made by the board of directors of ERI for a comprehensive investigation of the issue.  The Chairperson of ERI shall be responsible for managing  the investigation. The investigation shall be conducted either by appropriately experienced and independent members, directors, officers, employees or volunteers of ERI or by independent third parties, in either case selected by the board of directors of ERI.  The investigation is required to be conducted without regard to any person’s relationship, position or length or service with ERI.  All work of the investigation team shall be documented, including transcripts of interviews conducted.  The conclusion of all investigations shall be documented.  The person(s) that reported the suspicion of fraud or corruption shall be informed of the outcome of the investigation once the report and proposed course of action has been finalised.

  • Actions Arising from Fraud or Corruption Investigations

Persons  guilty of fraud or corruption have conducted gross misconduct.  Proven allegations of fraud or corruption may result in dismissal as a member, director, officer, employee or volunteer (as the case may be) of ERI.  Where appropriate, the ERI Board shall refer  fraud or corruption to the  civil authorities with a view to instituting criminal prosecution.  Where ERI has suffered loss, full restitution will be sought of any benefit or advantage obtained, together with the recovery of costs  from the individual(s) or organisation(s) responsible.

The names of the Executive Director, the Chairman of the ERI Board and Board members can be found on the ERI website:-