Anti-fraud and Anti-corruption Policy

• Fraud: deliberate deception, false representation, failure to disclose required information, or abuse of position intended to secure an improper gain or cause loss or risk of loss.

• Bribery: offering, promising, giving, requesting, or accepting anything of value to influence an improper action or decision. This includes facilitation payments.

• Corruption: misuse of entrusted power for private gain, including bribery, diversion of funds, collusion, nepotism, kickbacks, and abuse of influence.

• Facilitation payment: unofficial payment made to secure or speed up routine actions. Flaxur prohibits facilitation payments.

Flaxur prohibits, among other conduct:

• Theft, misappropriation, diversion of funds or assets.

• False invoicing, inflated pricing, ghost suppliers, duplicate payments.

• Falsified receipts, claims, timesheets, allowances, or reports.

• Kickbacks, commissions, or undisclosed benefits linked to procurement or contracting.

• Bribery in any form, including facilitation payments.

• Conflicts of interest that are undisclosed or improperly managed.

• Collusion in tenders, RFQs, supplier selection, or programme beneficiary selection.

• Misuse of organisational authority to override controls for personal benefit.

Governing oversight

Flaxur’s leadership and governing structures are responsible for setting the tone, approving this policy, and ensuring that risks are identified and managed appropriately. Where serious incidents arise, appropriate governance level reporting and decisions will be taken.

Management responsibilities

Management is responsible for implementing controls, promoting a speak up culture, ensuring training and awareness, and acting promptly on reported concerns. Management must ensure concerns can be raised safely and handled fairly.

All personnel and representatives

Everyone acting on behalf of Flaxur is responsible for:

• Understanding and complying with this policy.

• Avoiding and declaring conflicts of interest.

• Refusing and reporting bribes and improper requests.

• Reporting suspected fraud, bribery, or corruption promptly.

Flaxur uses proportionate controls to prevent and deter misconduct, including:

• Clear approval and authorisation rules for payments and commitments.

• Basic segregation of duties where feasible.

• Documented procurement and vendor selection practices.

• Due diligence checks for partners and suppliers where appropriate.

• Record keeping that supports auditability and traceability.

• Periodic review of higher-risk activities such as procurement, cash handling, and tender participation.

Flaxur recognises that culturally appropriate courtesy may occur. However, gifts or hospitality must never influence, or appear to influence, decisions.

Core rules:

• Gifts or hospitality that are excessive, frequent, linked to a decision, or requested must be refused and reported.

• Facilitation payments are prohibited.

• Gifts and hospitality must be recorded in a Gifts and Hospitality Register where applicable under Flaxur’s internal procedures.

• Any benefits offered by Flaxur to external parties must be legitimate, proportionate, and properly authorised.

Concerns should be raised as early as possible. Reports may relate to suspected or actual misconduct, attempted bribery, irregular procurement practices, financial anomalies, coercion, or pressure to bypass controls.

Flaxur supports good faith reporting and does not tolerate retaliation. Confidentiality will be maintained as far as reasonably possible while enabling a fair assessment and response.

Flaxur will take reports seriously and respond proportionately. This may include:

• Initial risk containment measures.

• Fact-finding and review.

• Appropriate internal action, including disciplinary or contractual measures.

• Remediation and strengthening of controls to prevent recurrence.

• Escalation to the governance level and external authorities where necessary and appropriate.

Unproven allegations must be treated as confidential. Flaxur will act fairly and avoid prejudging outcomes.

Fraud, bribery, and corruption are treated as serious misconduct. Confirmed wrongdoing may result in:

• Termination of employment, volunteer role, or contract.

• Recovery actions where feasible.

• Reporting to relevant authorities where required or appropriate.

• Withdrawal from partnerships or termination of supplier relationships.

This policy operates alongside:

• Conflict of Interest Policy

• Whistleblowing Policy

• Procurement and due diligence procedures.

• Financial controls and approvals.

• Data Protection Policy

• Information Security Policy

• Governance framework

This policy should be read in conjunction with:

• Data Protection Policy

• Privacy Policy

• Governance framework

• Other relevant internal policies

Together, these documents support Flaxur’s overall approach to responsible information management.

This policy is reviewed periodically and updated as Flaxur’s activities, risk profile, and regulatory expectations evolve. The current version will be published on the Flaxur website.

Concerns or enquiries relating to fraud, bribery, corruption, or unethical conduct can be raised via:

Email: compliance@flaxur.org