Anti-Bribery, Money Laundering & Terrorist Financing Policies
The Anti-Bribery, Policy was first drafted on 28 February 2021.
The following policy applies to all staff, volunteers, it’s associates, partners, consultants, contractors and anyone else who engages with The Gaza Fund in any capacity, at any point in time.
The Gaza Fund attaches the utmost importance to this policy and will apply a zero-tolerance approach to acts of bribery and corruption by anyone i.e., employees, volunteers, consultants, service suppliers or business partners working on our behalf.
- Every single person associated with The Gaza Fund is expected to declare any conflicts of interest prior to volunteering to work or help out at The Gaza Fund.
- Every individual associated with The Gaza Fund is also expected to safeguard and uphold The Gaza Fund’s core values by operating in an ethical and lawful manner at all times.
- Individuals are responsible for not giving or receiving bribes and challenging instances where bribery may occur by reporting all bribery that they are aware of, to firstname.lastname@example.org
CONSEQUENCE: Any member of staff found to have accepted or attempted bribery or made facilitation payments will be subject to disciplinary action, including dismissal.
DEFINITION: Bribery is the offering, promising, giving, accepting or soliciting of money, a gift or other advantage as an inducement to do something that is illegal or a breach of trust in the course of carrying out an organisation’s activities.
EXAMPLES: Bribes can take on many different shapes and forms but typically they involve corrupt intent. There will usually be a ‘quid pro quo‘ – both parties will benefit. Examples of bribery may include:
(1) A potential supplier offering money or a gift in order to influence a tendering process; or
(2) Facilitation payments which induce officials to perform routine functions they are otherwise obligated to perform.
RECORD-KEEPING: Many serious global bribery and corruption offences have been found to involve some degree of inaccurate record-keeping. The Gaza Fund maintains accurate records and financial reporting through its website, updated regularly. For details, visit https://thegazafund.com/our-expenses/
ANTI-MONEY LAUNDERING & ANTI-TERRORIST FINANCING STATEMENT:
The Anti-Money Laundering & Anti Terrorist Financing Policy was first drafted on 29 March 2021.
The following policies applies to all staff, volunteers, it’s associates, partners, consultants, contractors and anyone else who engages with The Gaza Fund in any capacity, at any point in time.
Broadly, money laundering is the process of concealing the illegal origin of proceeds derived from crime. Terrorist financing is the provision, collection or receipt of funds intending or knowing that those funds will be used to support or carry out an act of terrorism. While the money laundering and terrorist financing risk in the NGO sector is low, some charities, particularly those operating in crisis-hit regions, may be exposed to greater risks.
The impact of even one proven case will corrode public confidence in the affected charity and
the entire sector. It could also lead to charities experiencing transaction delays or denials or account closures by their banks due to concerns around money laundering and terrorist financing risks.
The Gaza Fund is committed to putting in place systems and processes to ensure that the charity is not used to launder money or finance terrorist activities, based on good practices.
To minimise our risk profile, we need to:
- maintain proper financial records of all donors as well as receipts of all expenses with a proper audit trails of decisions made.
- put in place appropriate internal financial controls to ensure that all funds are fully accounted for and are spent in a manner that is consistent with the charity’s purpose;
- take reasonable steps to ensure that the charity knows who its beneficiaries are, at least in broad terms, carry out appropriate checks in high risk situations and consistently apply clear beneficiary selection criteria.
- familiarise ourselves with the background and affiliations of our trustees, employees, fund-raisers, volunteers and other persons working on your behalf as well as of other persons with whom we work with closely;
- take reasonable steps to verify that our beneficiaries, donors and associates are bona fide and are not designated terrorists or subject to financial sanctions
- conduct financial transactions within mainstream financial channels such as bank accounts as far as is reasonably possible
- ensure The Gaza Fund is not infiltrated by banned groups (or banned individuals) and used to transfer proceeds of, and funds diverted to criminal activity;
- ensure not a single cent is raised for a terrorist cause or proceeds received by recipients that is later misused for terrorist purposes.
For details, visit https://thegazafund.com/our-expenses/
Use of Images Policy
We will try our best not to source, commission, purchase from stock image libraries or publish photographs that endanger and exploit vulnerable Palestinians, including women, girls and children.
While a picture says a thousand words, every effort will be made not to singularly use images to bolster fundraising. All images will also need to have accompanying text justifying the fund raising.
The key is to convey the urgent need for fundraising in an ethical way by meeting adequate standards in terms of dignified representation of people living in the Occupied Palestinian Territories and in Gaza.
To raise any concerns, email: email@example.com