IDRF is committed to conducting its business in a manner that represents the highest ethical standards, in accordance with all applicable laws, rules and regulations where the IDRF may conduct business. IDRF seeks to adhere to industry best practices with respect to anti-bribery and anti-corruption behaviour, and requires all Covered Persons to conduct themselves in a manner that does not violate these principles when performing their duties on behalf of IDRF and its stakeholders. In particular, IDRF is committed to full compliance with Canada’s Corruption of Foreign Public Officials Act (CFPOA), the United Kingdom Bribery Act (UKBA), the U.S Foreign Corrupt Practices Act (FCPA), and any local anti-bribery or anti-corruption laws that may be applicable to jurisdictions where the IDRF may conduct business.
This Anti-Bribery and Anti-Corruption Policy applies to all directors, officers, employees, contractors, consultants and volunteers of INTERNATIONAL DEVELOPMENT & RELIEF FOUNDATION, and each of its subsidiaries, affiliates and charter members (collectively, IDRF). Each such person is referred to as a Covered Person. IDRF will ensure this Anti-Bribery and Anti-Corruption Policy is brought to the attention of all Covered Persons.
Each Covered Person is responsible for understanding and adhering to this Policy and acting in a manner which will result in compliance with this Policy, including co-operating in any investigation of misconduct.
Adherence to this Policy and acting in a manner which will result in compliance with this Policy is a strict condition of continued employment or association with IDRF. It is not an excuse for non-adherence that the non-adherence was directed or requested by any other person.
For the purposes of this Policy, person means any individual, partnership, limited partnership, limited liability company, joint venture, syndicate, sole proprietorship, company or corporation with or without share capital, unincorporated association, trust, trustee, executor, administrator or other legal personal representative, governmental authority or other entity however designated or constituted.
Fraud describes a whole range of activities such as deception, bribery, forgery, extortion, theft, conspiracy, embezzlement, misappropriation, false representation, concealment of material facts and collusion. It involves the act of deceit against IDRF in order to obtain a personal or collective advantage, avoid an obligation or cause a loss.
Bribery is an offer, promise, or inducement of any kind offered or given to a person in a position of trust to influence that person’s view or conduct or to obtain an improper advantage. Examples of activities that may constitute bribery include, but are not limited to:
a) Bribing a person to act or fail to act in a manner that violates a legal duty;
b) Bribing a person to abuse or misuse his or her position;
c) Bribing a person in a position of influence within the public or private sector, foreign;
d) domestic, to secure an improper advantage, contract or concession; or
e) Making unusually large commission payments where a person acting as an agent or consultant does not appear to have provided significant services.
Corruption involves the act of dishonestly obtaining an advantage from a third party by abusing an entrusted power for private gain. Neither fraud, bribery nor corruption is restricted to monetary or material benefit, but could also include intangible benefits such as status or information.
Covered Persons should be aware that fraud, bribery and corruption may cover a wide range of activity including (but not exclusive to):
a) theft of assets;
b) misappropriation of funds;
c) misuse of IDRF’s assets (i.e., for example, using IDRF property privately without permission);
d) deception (e.g. misrepresentation of qualifications to obtain employment);
e) theft from a partner, customer, donor or supplier;
f) the theft or misuse of proprietary data or intellectual property;
g) providing favours or money to domestic or foreign legislative, administrative or judicial officials for personal or IDRF goals; and
h) providing contracts to third parties for the provider’s personal benefit.
IDRF prohibits all Covered Persons from participating in any activity that can be reasonably construed as fraud, bribery or corruption, for the purposes of creating an advantage in business, or the expectation of an advantage in business, for either IDRF or a third party for whom IDRF conducts business.
Covered Persons may not give or accept gifts or hospitality/entertainment in relation to IDRF and its business except in compliance with the following standards:
