ANTI CORRUPTION POLICY

The target group of this anti-corruption policy is all Mousawat employees.
As Mousawat employees, we are obligated to follow this anti-corruption policy and any breaches of this policy shall be reported through the Mousawat complaint mechanism (specifed below).
Corruption threatens good governance, sustainable development, democratic process, and fair business practices. Thus fghting corruption is building civil society and eliminating social injustice, which is in line with Mousawat’s vision:
“To help and be advocates of oppressed, neglected and marginalised groups in poor countries and to strengthen their possibilities of a life in dignity”
According to Transparency International’s Corruption Perception Index the countries that Mousawat operates in are among the countries most at risk to corruption in the world. Mousawat must secure that the funds we manage do not end up in the wrong hands.
Mousawat is entrusted with funds from a variety of donors and works to secure they are spent correctly and transparently. Mousawat holds a great responsibility to avoid corruption and secure that the funds are spent correctly toward donors, partners and benefciaries.
As employees of Mousawat we are responsible for upholding and promoting the highest standards of ethical and professional conduct. Working in different countries, sometimes in complicated and diffcult situations, among different languages, cultures and religions requires a lot from the employees. Knowledge, respect and common sense are some of the keywords that should be guiding our work.
The purpose of this anti-corruption policy is to support a behavior characterised by high standards of personal and organisational integrity, both internally and with other external stakeholders (partners).

General

Personal security and safety should never be compromised to live up to this policy.

As Mousawat staff we are responsible for following and abiding by the rules and regulations of national and international law. Furthermore we have to abide by the international conventions signed by the country, in which we operate.
It is the responsibility of Mousawat to inform partner organizations and other relevant stakeholders about this policy.

Anti-corruption principles

The following is a listing of the principles in Mousawat’s anti-corruption policy:

• Conflicts of interest
• Abuse of power and extortion
• Fraud and Embezzlement
• Bribery
• Nepotism and favouritism
• Gifts

1. Confict of interest

We will avoid any unexpedient conficts of interest – real or potential – between our personal interest and the interest of Mousawat.
Avoiding conficts of interest is the overall principle in fghting corruption. Confict of interest arises from situations in which you as a Mousawat employee have a private interest that could infuence your professional performance.
Conficts of interest can occur quite frequently and are not necessarily corrupt. It is how they are identifed and managed that is important. If confict of interest situations are not properly identifed and managed, they can endanger the integrity of Mousawat and can result in corruption. The staff member is expected to show good judgment and when in doubt, contact the superior. In questions of confict of interest it is important to use personal judgment and common sense to make the right decisions.

The following principles are all in some ways examples of conflict of interests

2. Abuse of power and extortion

We will not seek to infuence any person or institution for private purpose by using our offcial position or offering them personal advantages. Likewise, we will not use Mousawat property, facilities, services and fnancial resources for private purposes except when permission is given. We will not use any forms of extortion as a method to gain advantages.
This principle implies that you should not use your professional status for private gain. Misuse could be to gain advantages that you would not have gained otherwise. Relations to suppliers must not be used to gain reduced price on e.g. computers, cars, food, consultant support or travelling for private use. You are also not allowed to abuse your power as a manager to get personal favours or services done by employees.

3. Fraud and Embezzlement

Fraud and embezzlement are illegal and must not be used as methods to gain personal or professional advantages or property in relation to Mousawat, partner organisations or any other stakeholders.
Fraud is defned as economic crime involving deceit, trickery or false pretences, by which someone gains advantages or funds unlawfully. Embezzlement is defned as the misappropriation of property or funds legally entrusted to someone in their formal position as an agent or guardian.

Examples of fraud and embezzlement are false documentation, lying about qualifcations and abusing power/knowledge to steal cash and equipment from the offce, misusing funds entrusted to us.

Rules for accounting and documentation shall therefore be applied to at all times. E.g. approval of payments has to follow the “Accounting Manual for DCA Regional Offces” and approval of programmes and projects has to follow the “Programme and Project Manual” (PPM). All are expected to show honesty.

4. Bribery

We will not give or accept bribery in anyform.
Bribery is defned as the act of offering someone money, services or other valuables, in order to persuade him or her to do something in return. (Bribes are also called kickbacks, baksheesh, payola, hush money, sweetener, protection money, boodle, gratuity.)
One example is that we do not receive bribes from potential partners to make contracts with them and we do not give bribes to our partners as a way of infuencing. We base our cooperation with partner organisations on mutual ownership, accountability, participation, equality, harmonisation and alignment (Mousawat Partnership Policy for International Co-operation).
Bribery is illegal in all countries and harms the opportunities for fair trial and fair competition; it creates intransparent business markets that can be hard or impossible to access.


5. Nepotism and favouritism

We will not favour friends, family or other personal relations in recruitment, procurement, aid delivery or other situations.
Nepotism is favouritism toward relatives and friends, based upon that relationship, rather than on an evaluation of ability or suitability. For instance, offering employment to a relative or friend, despite the fact that there are others who are better qualifed and willing to perform the job, higher earnings, and other benefts to employees who are relatives of management.
To avoid favouritism and nepotism in procurement we follow the Mousawat Procurement Manual, access here:
www.Mousawat.com.
In recruitment at Regional Offces we follow the Mousawat “Recruitment policy for national staff” and in recruitment in Head Quarters we follow the recruitment policy.
It is important to underline that if conficts of interests are handled,it can be acceptable to hire/work with family or friends.

6. Gifts

We will not give or receive, directly or indirectly, any gift or other favour that may infuence the exercise of our function, performance of duty or other ways of possibly harming Mousawat. Gifts are defned as but not limited to services, travel, entertainment, material things or favours. In order to respect local traditions and conventional hospitality minor gifts are accepted.
The value of an acceptable gift varies over the countries in which Mousawat operates. Cash gifts are never accepted. All employees are expected to show good judgment and when in doubt, contact the superior. A rule of thumb is that a gift should never infuence your independent judgment and share the minor gifts that you accept with you colleagues.

The Mousawat complaint Mechanism

As Mousawat employees, we are obligated to follow this anti-corruption policy and report breaches of the policy. All corruption incidents in Mousawat, partner organisations or other incidents related to Mousawat activities must be reported into the complaint mechanism. If you get suspicion, hear rumours about corruption or experience any other doubt you can ask for advice here as well.
You need to fill in a complaint form and send it to mousawat.ngo@gmail.com.This e-mail box is only accessible for ExecutiveDirector. On basis of the complaint, it will be considered if an investigation committee will be set up and an investigation take place.
The complaint will be handled confdentially and with great respect for the complainant and the persons/organizations the complaint is pointing at. No anonymous complaints are accepted.
All incidents of corruption shall be reported in the complaint mechanism, also in cases where investigation has taken place regionally. Cases where personal security was at risk shall as well be reported in the complaint mechanism.

The complaint mechanism is accessed through Mousawats website

www.Mousawat.com

Annual anti-corruption report and corruption report

The annual “Anti-Corruption Report” is an attempt to summarise what Mousawat does to fght and prevent corruption with fnancial means administered by Mousawat. The report is published annually on the Mousawat’s website with the Annual Report.
A “Corruption report” is published on Mousawat’s website and updated within 48 hours. It describes in depth the cases of corruption and fraud that Mousawat has handled. Sensitive issues of personal character will never be published.
The objective is to inform openly about the problems envisaged with corruption in the countries we work in and to describe how we try to solve the problems and prevent them in future.
The reports and other relevant anti-corruption material and news are found at Mousawat’s website

www.mousawat.com.