Purpose

WWF International has a principle of zero tolerance to fraud and corruption. As an organization that condemns and fights fraud and corruption as one of the key drivers of poverty, environmental degradation and bad governance, it requires its own staff and all contracted parties to respect this principle at all times by fully conforming to all contractual terms, procedures and/or policies adopted to prevent fraud and corruption.

WWF is committed to handle promptly and firmly all allegations of fraudulent or corrupt activities, including investigating thoroughly where necessary, irrespective of whether these activities are attributed to WWF staff or to the contracted party. In certain cases, the actions of the contracted parties may cause WWF, its directors, officers and employees to be liable for these actions. Additionally, these allegations may lead to sanctions (including disciplinary actions up to and including summary dismissal, dismissal of officers, and termination of contract), and legal actions (including civil actions and criminal prosecution).

This Policy is intended to explain the standards of conduct that WWF expects from its contracted parties with respect to the prevention of fraud and corruption, and conflicts of interest, and to give guidance to its contracted parties on how to report any conduct that is prohibited under this Policy.

Scope

This Fraud & Corruption Prevention and Investigation Policy (“Policy”) applies to all contracted parties (including their officers, employees, advisors, agents and consultants) who enter into an agreement with WWF-International or any of the WWF offices, and who shall comply with the provisions of this Policy at all times.

In this Policy: “Contracted party” means any third party with whom WWF enters into an agreement, and includes (without limitation) grantees, implementing agencies, third party service providers (such as relocation agencies, customs brokers, etc.), consultants, agents, intermediaries, representatives, officials, contractors, suppliers, consultants, brokers, distributers, vendors, partners, lobbyists and activists, and other third parties contracted by, acting for, or providing services to WWF. “WWF-International” means WWF – World Wide Fund for Nature (formerly World Wildlife Fund), a Swiss foundation. “WWF offices” mean the field offices of WWF (e.g. Programme Offices and other offices reporting into WWF or the Programme Offices). “WWF” means WWF-International and WWF offices collectively.

Conduct Prohibited by this Policy

Fraud i.e. the act of deceit against the organisation in order to obtain a personal or collective advantage, avoid an obligation or cause a loss.

Corruption i.e. the act of dishonestly obtaining an advantage from a third party by abusing an entrusted power for private gain.

Bribery i.e. the offering, promising, giving, authorizing or accepting of any undue pecuniary or other advantage to, by or for a public officer or for anyone else in order to obtain or retain a business or other improper advantage.

Fraud and corruption are not restricted to monetary or material benefit, but could also include intangible benefits.

Examples of fraud and corruption:

• bribery, deception, forgery, extortion, theft, conspiracy, embezzlement, misappropriation, false representation, concealment of material facts, and collusion.
• theft or misuse of assets, proprietary data or intellectual property;
• deception (e.g. misrepresentation of qualifications to obtain employment);
• knowingly misrepresenting the costs, or financial status (e.g., through false financial statements) of an office, a project, an activity, etc., e.g., through falsified documents;
• providing favours or money to judges or other public officials to pursue personal or WWF goals;
• providing contracts to third parties for the provider’s personal benefit;
• fraudulent expense reports;
• misstatements of any accounts to any manager or to WWF’s auditors;
• paying a kickback (where the bribe is paid out of the contract proceeds themselves); conflict of interest that results in financial harm to WWF.

Gifts

All contracted parties should not accept or offer gifts, hospitality or benefits of any kind that might be seen to compromise their integrity or to be benefiting the person offering the service or the recipient personally and/or at the cost of WWF’s reputation. However, small gifts with no material value may be received or offered in appropriate situations provided there is no appearance of corruption, fraud or conflict of interest.

Conflict of Interest

All contracted parties shall not have any unauthorised conflict of interest with WWF or in the context of their performance of their agreement with WWF. Conflicts of interest can arise if a contracted party (including immediate family) has a close professional, financial, personal or other interest with a WWF employee or officer, or which is competing with the best interest of WWF. Should any such conflict arise, all contracted parties shall immediately disclose it in writing to the relevant WWF party. Failure to do so will constitute a breach of their agreement(s) with WWF and will entitle WWF to terminate their agreement with immediate effect, without prejudice to and in addition to any remedies or other rights provided by law and/or statute and/or under any other provision of their agreement for the benefit of WWF.

Contracted parties’ responsibilities

When working with or on behalf of WWF, contracted parties must have, and be seen to have, high standards of integrity.

Each contracted party has a duty to ensure that the funds provided/granted by WWF are safeguarded and used for the purposes intended by WWF, and to report immediately if they suspect any fraud has been committed or they see any suspicious acts or events (see investigation section below). Contracted parties should assist in any related investigation by making available all relevant information and by co-operating with investigators (e.g., interviews, provision of documentation, etc)

Contracted parties shall ensure that appropriate measures are in place within their organization to effectively prevent, deter, detect and communicate potential fraud, corruption and conflict of interest.

In particular, under no circumstances should any payments or anything of value be made, promised or offered to any government employee in violation of this Policy and in contravention of applicable laws in the relevant country. Furthermore, no assistance, payments or anything of value (monetary or non-monetary) should be made, promised, offered to, or accepted from any government employee or official to:

• influence any official government act or decision;
• induce any government employee or official to do or omit to do any act in violation of his/her lawful duty;
• obtain or retain business for, or direct business to any individual or entity.

Even if it is locally common practice to provide bribes, or if the contracted party receives the assurance that the payment is permitted under local laws, any requests to provide an advantage, cash payment, gift or entertainment, or any other behaviour covered by this Policy should be:

• reported as described in this Policy.

Warning Signs

• abnormal cash payments, or lavish gifts being received;
• an individual who never takes time off, or holidays, or insists on dealing with specific contractors himself or herself;
• unauthorized signature of consultant contracts during management’s absence;
• missing documents or records regarding payments, expenses, meetings or decisions.

 WWF Fraud and Corruption Prevention and Investigation Policy 2 Contracted party version 1.3 - Sept 2015