Anti Fraud Policy &

Complaint Response Mechanism

(CRM)
November 2014
 Concern Worldwide

Working in Pakistan since 2001 in Emergency Response and

Development
OFDA Funded project Rapid Fund since 2009
CBDRM project since 2011
Other major Donors included ECHO, DFID and EU.
 Commitment to Accountability

Accountability: Accepting responsibility for

doing what we say we will do;
being open and transparent about what we do,
why and how we do it; and
responding promptly to complaints or concerns about our work.
Concern is committed to being accountable to our stakeholders
Concerns 2005 Governance Framework and Strategic Plan 2011-2015
commit accountability to its beneficiaries
In 2007, Concern joined the HAP-international self-regulatory body &
committed to meeting the highest standards of accountability.
 Policy Framework

Programme Participant Protection Policy Revised

2010
Anti Fraud and Whistle blowing Policy 2011
Investigation Guidelines 2011
Anti Fraud Strategy approved in 2013
Complaint Response Mechanism revised - 2013
 Scope of Anti-Fraud and CRM Policy

Our Anti-Fraud, P4 and CRM policy is aimed at to empower the following

stakeholders to lodge a complaint for any issue.
Beneficiaries
Suppliers
Employees
Employees of our Partner organizations
General Community
Any other individual who is aware of any issue that needs to be
resolved.
 How to lodge a complaint?

Complaint
sSuggestio
ns
Complain Email
t Box
sBy
Communit In
Phon Community Rep
y Meetings Person
e

Analysis and Investigation of the

complaint
 Communicating our
Complaint Response Mechanism

P4, Anti Fraud and CRM policy along with Concerns complaint hotline
number is part of
All agreements with Partners (I/NGOs)
All advertisements for procurement
All Bid Documents
All Agreements with Suppliers
Banners/posters on How to Complaint are displayed in each
project area to inform/educate beneficiaries
Partners orientation on CRM and Anti-Fraud policy required to
report any suspected/fraud as per partnership agreement
In field visits beneficiaries are directly told about their right to
complaint and the contact details
Responding to Complaints
 Sensitive and non-sensitive complaints

Valid complaints are of two types:

1. Non-sensitive complaints include:
Beneficiary selection criteria
Quality and/or quantity of supplies and services
provided by Concern or its partners
Lack of adequate information
Inefficient service delivery mechanisms
Level of partner and/or Concern presence in the
community
Decision making processes in the community
 Sensitive and non-sensitive complaints

2. Sensitive complaints include:

Fraud and corruption i.e. breach of Concerns Anti-fraud
Policy
Work place Harassment including sexual harassment
Abuse of power by any stakeholder
Breach of confidentiality
Discrimination
Security risk to the organisation or its staff
 Principles of CRM

Safety
Confidentiality
Transparency
Accessibility
 Conducting Investigation

CD/HQ establishes an investigation committee with formal

ToRs (For serious allegations like fraud, HQ informs the
donors)
Senior and Independent personnel appointed for sensitive
complaints
Timely and thorough investigation is conducted into each
complaint
Final report is submitted to CD and HQ
CD / HQ informs Donor agency- actions are taken and
reported to the donor agency
 Investigation key actions

Reviewing all relevant documentation

Meeting with complainant, subject of complainant and other
witnesses/relevant people
Independent verification of the subject matter i.e. fresh
quotations from the market to verify price of materials
procured
Thorough checks performed to reconcile documentation
with Tax Authorities, Motor Vehicle Registration Authority,
and NADRA
 Challenges

Capacity of local partners to implement CRM

Lack of policies and procedures at Partner level
Lack of trained staff to carry out investigations
Lack of trained staff to implement a robust CRM
Capacity of staff in checking documents with a forensic investigator
mindset
Limited trained staff for implementation of CRM and conducting
investigations
Number of complaints received is very high, most of which are not valid
Resources required like time, financial and HR
 Conclusion

We aim to design our procedures/systems to minimize

misuse of funds/resources and instances of fraud
We make changes to our controls / systems based on the
weaknesses highlighted through CRM
Strict disciplinary actions are taken in proven cases of
fraud/harassment dismissal of staff; termination of
partnership with partners