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Anti Fraud Policy


Introduction     3

Definitions       4

  • What is Fraud?
  • What is Bribery & Corruption?
  • What is a Facilitation Payment?
  • Kickbacks?
  • Payments under Duress?
  • What are ‘Gifts and Hospitality?’

Policy Statement       5-6

  • Facilitation Payments and ‘Kickbacks’
  • Payments under Duress
  • Gifts and Hospitality

Responsibilities         7

  • Board of Directors
  • Senior Staff and Managers
  • All Employees
  • Responsibility of the Organisation

Reporting and Investigation             8

Training and Communication            8

Annual Appraisal                               8

Disciplinary Sanctions                       8

Associated Policies and Procedures             9


The purpose of this Policy is to is designed to ensure that all incidences of fraud and corruption are identified and addressed in an appropriate and timely manner

This Policy applies to AVA Capital Group (“the company”), all employees, including affiliate organizations, and to all paid and unpaid consultants, contractors, interns, secondees, and volunteers that provide supplies, services, or support, to the company or promote its work at any location in or out of Ireland. All such parties are referred to as “employees” in this document.

This Policy also applies to the company’s partners, vendors, and other third parties, where it is included or referenced in the relevant bid or tender documents, agreements, memorandums, purchase orders, or contracts.

The company is committed to acting professionally and fairly in all of its dealings and relationships, employing the highest standards of openness, transparency, and accountability, and takes a zero-tolerance approach to fraud, bribery, and corruption.

The company promotes a culture of honesty and integrity and totally opposes any form of fraud, bribery, or corruption. Fraud, bribery, and corruption impact disproportionately on the poor and the most vulnerable people in the world. Such criminal activities divert resources intended for humanitarian assistance and development away from our intended beneficiaries; they increase the costs of basic public services, and undermine economic growth. Such actions are a barrier to poverty alleviation and good governance.

The purpose of the Anti-Fraud and Anti-Corruption Policy is to provide clear definitions of what we mean by fraud, bribery and corruption. It is also a definitive statement to everyone associated with the company – making it clear that we will not tolerate fraudulent or corrupt activities, and the giving or receiving of bribes. This policy summarizes the responsibilities of all the company’s staff and Board members to adhere to and uphold the company’s position on fraud, bribery and corruption.

The company’s Board(s) and Senior Management Teams are committed to the implementation of this policy and to ensuring that training and support is provided to all employees and Board members on its content, and on their individual and collective responsibilities.


What is Fraud?

Fraud is used to describe a range of illegal activities. These include, but are not limited to, deception, forgery, theft, the false reporting or concealment of material facts, collusion and corruption (including bribery) and undeclared conflicts of interest

Examples of fraud other than bribery, include, but are not limited to:

  • Theft of money, property or assets
  • Inappropriate use of company assets
  • Submitting false expense claims
  • Forging, tampering with or falsely creating documents or records
  • Destroying or removing documents or records
  • Knowingly creating or distributing false financial information or reports
  • Engaging in bribery or corruption
  • Deliberately ignoring or acquiescing in fraudulent activity

What is Bribery & Corruption?

Bribery and corruption have a range of definitions in law. The following is a plain language guide:

Bribery: The offering, promising, giving, accepting or soliciting of money, gifts or other advantages

in exchange for doing something illegal or breaching an employer’s trust.

Corruption: The abuse of entrusted power or influence for private gain.

The following are some examples of attempted bribery:

  • A potential supplier offers money or a gift to influence a procurement/tender
  • A job applicant offers payment or a gift to increase his/her chances of being
  • A gift (e.g. excessive hospitality) offered to a local official in return for approving a
  • A potential or actual beneficiary offers a payment in return for allowing him/her or their family to be given aid to which they are not
  • A government official asks for a payment to secure an NGO
  • A customs official asks for an unofficial payment or gift to release

What is a Facilitation Payment?

The final two bullets above could be examples of facilitation payments, which are usually a bribe in the form of a small, unofficial payment. It is made to secure or expedite the performance of a routine or necessary action to which the person making the payment has legal or other entitlement,

e.g. an unofficial payment made to a border guard/officer in return for a speedier crossing.


Kickbacks are typically payments made in return for a business favor or advantage.

Payments under Duress?

Payments made under duress are in response to demands accompanied by threats to life, limb, or liberty.

What are ‘Gifts and Hospitality?’

These can range from small gifts or promotional materials (such as diaries and pens) to expensive hospitality (such as a holiday). Extravagant gifts and hospitality may be thinly-veiled bribes intended to induce improper behavior.


Fraud, bribery, or corruption in any form will not be tolerated by the company. Where criminality occurs, the loss is not just to AVA Capital Group but, much more importantly, to the company’s beneficiaries who are some of the poorest and most vulnerable people in the world. It may also have a major impact on the company’s reputation and, as a consequence, donor confidence in the company.

This, again, ultimately impacts our beneficiaries. The company will conduct, manage, and monitor all aspects of our work in a way that reduces and hopefully eliminates opportunities for fraudulent or corrupt activity, including the giving or accepting of bribes.

Facilitation Payments and ‘Kickbacks’

All employees and Board members must avoid any activity that might lead to a facilitation payment being made or accepted by or on behalf of the company. The company prohibits the making or accepting of facilitation payments and ‘kickbacks. If someone suspects a payment request to be solely for the purposes of facilitation, they should ask that a detailed receipt be provided. If there appears to be no legitimate reason for a request for payment, it should be explained that the company does not make or accept facilitation payments. If an employee feels it is safe and appropriate to do so, they should ask to speak to the supervisor of the person requesting the payment. If a receipt can be provided and the employee does not suspect the payment is for the purposes of facilitation, payment will be allowable. 

Payments under Duress

It is permissible for a payment to be made in the rare and exceptional circumstances where it is believed necessary to protect against loss of life, limb, or liberty (except in the case of lawful detention). If possible, the circumstances and proposed payment should be discussed in advance with a line manager. In all such cases, an incident report must be submitted.

Gifts and Hospitality

The giving or receiving of gifts (other than those deemed to be small promotional items) by or on behalf of the company is not permitted under any circumstances. The company and Board members must exercise great caution when offering or accepting hospitality and entertainment.

They must be certain that what is being offered is not designed to gain an improper benefit or does not otherwise amount to bribery or corruption.

The providing or accepting of hospitality or entertainment is allowed, as long as:

  • It is not done with the intention of influencing the behavior of the recipient;
  • It is done openly;
  • It complies with local

If a member of staff or Board wishes to offer entertainment or hospitality, it must be authorized by a senior manager in advance.


The Board members, Senior Management, Managers, and employees at every level are responsible for protecting the company and the communities we serve from the impact of fraud, bribery, and corruption by always acting in accordance with this policy.

Board of Directors

The Board is responsible for ensuring that the organization has a properly functioning internal control and risk management system and expects that all instances of fraud/corruption are brought to its attention by management.

Senior Staff and Managers

It is incumbent upon the managers and senior staff to set an example by complying fully with the company’s policies, procedures, and controls. Managers and senior staff are responsible for ensuring that employees under their charge are trained upon and fully understand the company’s Anti-Fraud and Anti-Corruption Policy, and the consequences of non-compliance.

Senior staff and managers must be familiar with and alert to the types of fraud that might occur in their area(s) of responsibility. In particular, they must:

  • Ensure that this policy and all the company’s systems, financial controls, and procedures are fully understood by staff;
  • Frequently check that these are being fully observed and implemented;
  • Regularly review and, where necessary, update control and

All Employees

It is the responsibility of every employee to carry out their work and conduct themselves at all times in such a way as to prevent fraud, bribery, and corruption. All employees and Board members must be alert to and report any actual or suspected instances of fraud, bribery, and/or corruption. 

Responsibility of the Organization

Periodic Risk Assessments: The Audit and Risk Committee shall regularly (at minimum, once a year) assess risks, including those covered by this policy; assess, update and record existing and potential risks to the organization’s human and material assets.


If someone connected to the company is offered or asked to pay a bribe, they must refuse and explain that bribery runs totally counter to the company policies. If someone suspects that fraud, bribery or corruption is, has, or is likely to take place, they must at the earliest opportunity report the matter via the line manager and/or the company’s Whistleblowing Policy. The interests and well-being of those making a report will be fully protected by the company’s Whistleblowing Policy.

Failure on the part of an employee or Board member to report suspicions may lead to disciplinary procedures being instigated, up to and including dismissal and/or legal proceedings. If an employee knowingly lodges a false report, this will be regarded as a serious disciplinary offence and dealt with in accordance with the company’s disciplinary procedures.

Investigating reports of fraud will be as per the company’s Serious Wrongdoing Reporting and Investigation procedures.


As part of the induction given to new staff and Board members to any entity, the company will effectively communicate and provide training on our Anti-Fraud Policy. Ongoing refresher courses and training on anti-fraud will also be conducted. 


Completion of training on anti-fraud and ensuring that senior staff (and those under their charge) are compliant with this policy will form part of the company’s annual performance appraisals.


Violations of this policy will be dealt with in accordance with the company’s Disciplinary Procedure and may result in sanctions, up to and including termination of employment.


The Anti-Fraud and Anti-Corruption Policy is linked to and must be read in conjunction with:

  • AVA Capital Group Whistleblowing Policy

The company reserves the right to report any suspected criminal activity to the relevant legal authorities.

Approved this 10th day of May 2019