RESPONSIBILITY: Hromadahub Board
DATE ISSUED: 1 September 2022

The scope of this Policy and Procedure applies to every Hromadahub employee, volunteers, workers, contractors, consultants, interns and agents including senior executive and financial officers, and Board members , and reflects the standard to which the foundation expects it partners, agents, contractors, and consultants to adhere when acting on the foundation’s behalf.This policy provide  information and guidance to those working for Hromadahub on how to recognise and deal with fraud, bribery and corruption.This Policy is intended to supplement all applicable laws, rules, and other foundation policies.

It is the responsibility of the Senior Managment Team  (“SMT”) and the designated officer to ensure the following Policy  is adhered to. The SMT shall review this Policy on an annual basis for appropriateness, compliance internally with the foundation and for compliance with all applicable standards, acts, legislation, etc.Requests for additional guidance or interpretation regarding this Policy can be directed to the SMT or designated officer.It is the responsibility of all SMT to ensure the functionality and accuracy of this Policy is adhered to.It is the responsibility of every employee, volunteer, worker, consultant, agent to ensure the functionality and accuracy of this Policy is adhered to.It is the responsibility of the SMT and the designated officer to ensure that a risk assessment and due diligence are conducted prior to the appointment of a third-party intermediary.Where the guidance in this policy conflicts with any applicable laws or regulations, the higher standard must at all times be observed, so that Hromadahub is compliant with all applicable laws and regulations.

Corruption: Corruption is the abuse of entrusted power for private economic gain. This Policy will refer to both as “bribery.”Bribery: Bribery is the giving, offering or agreeing to provide benefits to others in order to improperly influence an outcome to obtain or retain an advantage. Bribery can take many forms, including the provision or acceptance of:cash payments
phony jobs, shell companies, or “consulting” relationships
political or charitable contributions
social benefits, or
gifts, travel, hospitality and reimbursement of expenses
Fraud: An act of deception intended for personal gain to obtain an advantage, avoid an obligation or to cause loss to another party even if no such gain or loss is in fact caused. For the purpose of this policy, fraud also covers the dishonest appropriation of property belonging to another, with the intention of permanently depriving them of it.embezzlement: improperly using funds, property, resources, or other assets belonging to Hromadahub for their own personal advantage instead;collusion: improperly colluding with others to circumvent, undermine, or ignore our rules, policies, or guidance (e.g. fixing the amounts of a tender in order to bring it below a certain threshold);abuse of a position of trust: improperly using one’ s position within Hromadahub for personal benefit (e.g. accessing confidential material or passing confidential information) or with the intention of gaining from, unfairly influencing or depriving the organisation of resources, money and/ or assets;nepotism or patronage: improperly using employment to favour or materially benefit friends, relatives, or other associates, or where someone requests that Hromadahub employee offer employment or some other advantage to a friend or relative (e.g. awarding contracts, jobs, or other material advantages);false accounting: deliberately entering false or misleading information into accounts or financial records (e.g. entering false refunds or voids through the till in a retail shop);
false invoicing:  knowingly creating or using invoices that are false in any way;
expenses fraud: dishonestly using the expenses system to pay money or other benefits to which the recipient is not entitled;payroll fraud: dishonestly manipulating a payroll system to make unauthorised payments (e.g. by creating ‘ ghost’ employees or by increasing an individual’ s salary);
tax or duty evasion: knowingly avoiding the payment of tax or any other duty that a person is aware should be paid;forgery: dishonestly creating or altering documents to make any information in the document incorrect or misleading often with the effect of depriving the organisation of resources, money and/ or assets;brand fraud:  dishonestly using Hromadahub name, branding or documentation for personal or private gain;obstructing proper process: threaten or retaliate against another individual who has refused to commit a bribery offence or who has raised concerns under this policy;failing to disclose information:  not providing accurate and complete information relevant to your position which will adversely impact your ability to perform your role;  for example, failure to disclose a ‘ conflict of interest’.

Hromadahub takes  a “zero tolerance approach” to fraud, bribery and corruption, which
means Hromadahub is committed to the highest standards of corporate governance, fiduciary duty, responsibility and ethical behaviour. Fraud, bribery, and corruption diminishes undermining the viability of our organisation, and breaching the trust placed in us by our donor community.Hromadahub has a responsibility to keep our Donors and Members fully informed and promptly updated on any suspicion of fraud relating to their funds.All Hromadahubemployees are responsible for taking all necessary and appropriate steps to prevent, deter, and detect fraud, bribery, and corruption within their areas of responsibility.Any employee, who violates the terms of this Policy will be subject to disciplinary action.Any employee who has direct knowledge of potential violations of this Policy but fails to report such potential violations to foundation SMT/ the designated officer will be subject to disciplinary action.Any employee who misleads or hinders investigators inquiring into potential violations of this Policy will be subject to disciplinary action.In all cases, disciplinary action may include termination of employment.Any third-party agent who violates the terms of this Policy, who knows of and fails to report to SMT / the designated officer potential violations of this Policy, or who misleads investigators making inquiries into potential violations of this Policy, may have their contracts re-evaluated or terminated.

All new employees, volunteers, consultants, contractors, agents will receive a copy of this Policy in their on-boarding packages.All employees will receive an annual reminder and overview of the Policy during annual training.

Any payment or offer of payment to an official for the purpose of influencing that official to assist in obtaining any advantage for a foundation is strictly prohibited. A “payment” under the respective bribery and corruption laws is broadly interpreted to include not only the actual payment of money, but also an offer, promise or authorization of the payment of money, as well as an offer, gift, promise or authorization of the giving of “anything of value.” “Anything of value” may include not only cash and cash equivalents, but also gifts, entertainment, travel expenses, accommodations and anything else of tangible or intangible value. Application of the law is not only to payments or offers to pay, but also to any act or event that is “in furtherance of” a payment to an official. Even if an improper payment is not consummated, just offering it violates these laws. Likewise, it is a violation of these laws to instruct, authorize or allow a third party to make a prohibited payment on the foundation’s behalf, or to ratify a payment after the fact, or make a payment to a third party while knowing or having reason to know that it will likely be given to a government official.Foundation employees are strictly prohibited from offering, paying, promising or authorizing, directly or indirectly, any financial or other advantage or benefit to officials or  foreign officials, candidates or parties for the improper performance (whether it be an act, omission, use of influence or otherwise) of a relevant function or activity.

In addition to its improper payment provisions, certain accounting requirements are imposed on the foundation. Specifically, it is required that a foundation maintains books, records and accounts that, in reasonable detail, accurately reflect the transactions and dispositions of the foundation. In order to comply with these requirements, it is imperative that foundation employees, officers and agents maintain complete and accurate records with respect to all transactions undertaken on behalf of the foundation. These requirements apply to transactions of any amount, not just sums that would be “material” in the traditional financial sense. “Records” include virtually all forms of business documentation, including accounts, correspondence, memos, tapes, discs, papers, books and other documents or transcribed information of any type.

The following uses of Hromadahub funds or assets are prohibited:

Direct or indirect payments, gifts, contributions, or offers or promises of anything of value in the form of bribes, kickbacks, or any other attempt to purchase services or win a tender, including, but not limited to, inducements to obtain orders to sell the company's services  . Any other direct or indirect payments, gifts, donations, offers or promises of anything of value may be made only to the extent that they are in accordance with reasonable practice approved in each case by the designated official of the foundation. The provision of discounts to legitimate customers or partners in the normal course of business is not prohibited, provided that such discounts are properly approved, documented and accounted for. Commissions, fees, or similar payments which are not reasonably related in value to the services rendered, or commissions, fees or similar payments made in exchange for services rendered which are illegal or in any manner violate this Policy.

Direct or indirect contributions of money, property, or resources to the campaign of a candidate for office in the Government or in any national political party, other than as permitted by law.

Use of assets, funds or resources of the company by employees or members of their family, which is personal, or not in furtherance of the business of the foundation.