Society for (ACACF) Pakistan

Anti-Fraud Policy

SAFEGUARDING POLICY of ACACF
Definition of Safeguarding:
ACACF Pakistan introduces safeguarding policy to protect, people with whom it works or
whomever work for ACACF-Pakistan, from any form of harm, bullying, harassment, exploitation,
abuse, neglect or any other act that may cause injury or suffering.
Scope and Application of Safeguarding Policy:
The safeguarding policy is applicable to everyone concerned or related to ACACF-Pakistan
in any way but not limited to its staff, grantees, partners, associates, board members,
beneficiaries, program participants, volunteers, venders, consultants, interns, resource persons,
or whosoever connected with organization one way or the other.
The safeguarding policy is applicable to be part of terms and conditions / clauses, in all contracts
with partner organizations, vendors, staff, interns and consultants etc.
The safeguarding policy especially protects vulnerable groups like women, children,
people living with disability, sexual minorities, religious minorities, young people, scheduled
castes, survivors of gender-based violence and other socially excluded groups.
This safeguarding policy is, therefore, fundamental to ACACF Pakistan’s professional integrity. In
addition, it reinforces the value that it places on all people associated with ACACF Pakistan to
feel protected against any type of discrimination on the basis of gender identity, sexual
orientation, ethnicity, income, social status, race, caste, creed, color, physical appearance,
disability or any other feature.
It also provides a method of properly addressing bona fide concerns that individuals or
groups within or outside of organization might have.
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ACACF Pakistan’s management shall appoint a designated Safeguarding Focal Point and publicize
his/her name for recording / investigation or complaints / concerns etc.
ACACF Pakistan’s management shall formulate a designated Safeguarding Committee for follow
up, redressals and risk management and assessments etc.
Fundamental Elements of the Policy:
Any harmful incident may be reported, highlighted or noticed by any concerned person
associated or connected with the organization as defined above
ACACF Pakistan requires the concerned person(s) to identify themselves by providing their
name, CNIC number and phone number for follow up and support.
The concerned person or whistleblower shall b e protected from victimization,
harassment or disciplinary action as a result of reporting; where the report is made in good
faith and is not made maliciously or for other unjustified reasons.
Reported matters shall be investigated fully and formally including interviews with all
the witnesses and other parties involved. The identity of the concerned person shall be held
confidential at all stages by the Safeguarding Committee.
ACACF Pakistan shall provide internal anonymity; it cannot guarantee such a
confidentiality will be retained if any external legal actions would follow.
Reporting Information & Documentation
If the circumstances require, the issue may be reported to Ms. Sama (ALAC-lawyer) –
Safeguarding Focal Point by the victim/ complainant / concerned person personally or via Phone


In case the victim/ complainant / concerned person requires to submit his /her complaint
or instance against higher management of the organization or not comfortable to report to Mr.,
Safeguarding Focal Point he/she may complaint to Ms./Mr. Board Member, (Hazrat Ali (GS) at
hazratali@ACACF-pakistan.org, S/he will initiate the process of the investigation / redressal
immediately as per procedure.
The Safeguarding Focal Person shall maintain a Log Incident Register for immediate
registration of incident and then initiate the further investigation or redressal process with the
support of Safeguarding Committee members
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The Safeguarding Focal Person reviews the instances on monthly basis and prepares the
analysis report on monthly basis to share the findings with Management Committee during
monthly/ periodic meetings of MC.
The annual analysis report may also be consolidated by Safeguarding Committee and
learning may be shared with board members for appropriate policy changes / SOPs reforms etc.
The Log Incident Register shall be safely kept in the custody of Safeguarding Focal Person
and the Head of Human Resource Department or any member of the Safeguarding Committee
shall inspect the register on periodic basis.
Safeguarding Committee and its Role
The Safeguarding Committee shall comprise of;

  • One member from the senior management of the organization
  • Head of / Director/ Manager HR and;
  • Safeguarding Focal Point
    In cases, where needed, a Board Member can be requested to be part of the committee or
    for the oversight of the process and redressal. The Head of / Director /HR will be secretary of
    all meetings, and will be kept in the loop throughout the proceedings of the case or complaint.
    The Safeguarding Focal Point will be responsible for maintaining the record and
    documentation of all such proceedings. If any one of the members of the Safeguarding
    Committee is a victim or complainant or accused, then he or she will be replaced on the
    Committee for that case by the Management or Board.
    After conducting investigations, if the Safeguarding Committee feels that the issue
    raised by the concerned person/ whistleblower is critical to the operations of ACACF
    Pakistan and threatens to have pervasive negative implications, the Committee will escalate
    the matter to the C E O a n d Board of Directors for further deliberation.
    The Board members will take up the case as per the policies and procedures of the
    organizations or as per the law of land.
    The members of the Safeguarding Committee shall also review the Risk Register of the
    organization on periodic basis to pre-empt the prospective harms and suggest mitigation. The
    risk register may also share the learning from the past instances that can be inculcated in the
    future plans.
    The safeguarding policy shall be reviewed annually during the annual review and planning
    meeting of the organization. The recommendations shall be shared with Board members for
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    improvements and amendments accordingly
    The focal point and members of the Safeguarding Committee shall be provided with
    specialized trainings at the time of induction and later, on periodic basis to equip them with
    modern day’s harmful practices to pre-empt ensure protection and do no harm at all levels.
    All the staff / board members shall be given orientation on safeguarding policy and SOPs
    at the time of induction.
    In case of engagement with children below the age of 18 consent of their parents/
    guardian/custodian shall be attained
    Photographs and videography of all the organizational events and their further use at all
    publications / social media / electronic media / print media shall be made with the consent of
    participants in order to safeguard their privacy and identity.
  • Any dishonest or fraudulent act
  • Misappropriation of funds, securities, supplies, or other assets
  • Impropriety in the handling or reporting of money or financial transactions
  • Profiteering as a result of insider knowledge of organizational activities
  • Disclosing confidential and proprietary information to outside parties
  • Disclosing to other persons securities activities engaged in or contemplated by the organization
  • Accepting or seeking anything of material value from contractors,vendors, or persons providing services/materials to ACACF, beneficiaries, refugees and/or stakeholders Exception: Gifts less than Rs. 500 in value.
  • Destruction, removal, or inappropriate use of records, furniture, fixtures, and equipment; and/or
  • Any similar or related irregularity

OTHER IRREGULARITIES
Irregularities concerning an employee’s moral, ethical, or behavioral conduct should be resolved by the immediate supervisor, Field Manager and/or Project Manager. If there is any question as to whether an action constitutes fraud, contact the Director of Administration for guidance.
INVESTIGATION RESPONSIBILITIES:
The Administration Unit has the primary responsibility for the investigation of all suspected fraudulent acts as defined in the policy. If, the investigation substantiates that fraudulent activities have occurred, the Investigation Committee will issue reports to appropriate designated personnel and, if appropriate, to the Chairman of the board or his nominated person for verification of the facts and endorsement of recommendations.
Decisions to prosecute or refer the examination results to the appropriate law enforcement and/or regulatory agencies for independent investigation will be made in conjunction with legal counsel and senior management, as will final decisions on disposition of the case.
CONFIDENTIALITY
The Admin Unit treats all information received confidentially. Any employee who suspects dishonest or fraudulent activity will notify the Admin Unit immediately, and should not attempt to personally conduct investigations or interviews/interrogations related to any suspected fraudulent act (see REPORTING PROCEDURE section below).
Investigation results will not be disclosed or discussed with anyone other than those who have a legitimate need to know. This is important in order to avoid damaging the reputations of persons suspected but subsequently found innocent of wrongful conduct and to protect the organization from potential civil liability.
AUTHORIZATION FOR INVESTIGATING SUSPECTED FRAUD
Members of the Investigation Committee will have:

  • Free and unrestricted access to all organizational records and premises, whether owned or rented; and
  • The authority to examine, copy, and/or remove all or anyportion of the contents of files, desks, cabinets, and other storage facilities on the premises without prior knowledge or consent of any individual who might use or have custody of any such items or facilities when it is within the scope of their investigation.

REPORTING PROCEDURES
Great care must be taken in the investigation of suspected improprieties or irregularities so as to avoid mistaken accusations or alerting suspected individuals that an investigation is under way. An employee who discovers or suspects fraudulent activity will contact the Admin Unit immediately. The employee or other complainant may remain anonymous. All inquiries concerning the Activity under investigation from the suspected individual, his or her attorney or representative, or any other inquirer should be directed to the Investigations Unit or the Legal Department. No information concerning the status of an investigation will be given out. The proper response to any inquiries is: “I am not at liberty to discuss this matter.” Under no circumstances should any reference be made to “the allegation,” “the crime,” “the fraud,” “the forgery,” “the misappropriation,” or any other specific reference.
The reporting individual should be informed of the following:

  • Do not contact the suspected individual in an effort to determine facts or demand restitution.
  • Do not discuss the case, facts, suspicions, or allegations with anyone unless specifically asked to do so by the Legal Department or Admin Unit.

TERMINATION
If an investigation results in a recommendation to terminate an individual, the recommendation will be reviewed for approval by the designated representatives from Human Resources and the Legal Department and, if necessary, before any such action is taken. The Investigation Committee does not have the authority to terminate an employee. The decision to terminate an employee is made by the chairman ACACF. Should the Admin Unit believe the Investigating committee decision inappropriate for the facts presented, the facts will be presented to the chairman for a decision.
ADMINISTRATION
The Manager Administration is responsible for the revision, interpretation, and application of this policy with the consent of the chairman office. The policy will be reviewed annually and revised as needed.