Whistle Blowing

Introducing the ACBF Whistle Blowing System

What is whistle-blowing?
Whistle blowing is the process of notifying on incidents or suspected incidents of fraud, corruption or malpractice on ACBF funded activities and operations by contacting the Foundation either anonymously or openly through the established and confidential system. Such notifications are guided by the Fraud and Corruption Prevention Policy which emphasizes that ‘’ACBF is committed to promoting and adhering to the highest standards of probity and accountability in the use of public resources and takes zero-tolerance stance towards cases of fraud and corruption in ACBF funded activities and operations.’’

Notification of incidents on fraud, corruption and malpractice may come from ACBF personnel, grantees and their personnel or other external parties. ACBF personnel have the obligation to disclose any fraud or corruption that comes to their attention immediately but in any event not later than seven (7) days after becoming aware of the fraud or corruption.

What issues can be addressed through the whistle blower System?
The ACBF whistleblower system is for reporting wrongdoing that can impede the delivery of results by ACBF as an institution, and all the funded projects or programs in achieving stated objectives. Issues may include but are not limited to misuse of ACBF grant proceeds, falsifying documentation and signatures, personal use of project/program assets, manipulating tender/order and splitting to avoid tendering, accepting late tenders, collusion with suppliers and processes to achieve desired results, manipulating selection processes for staff appointments.

The whistleblower system is not for reporting personal grievances, as such cases can be referred to the ACBF Human Resources Department or management of the respective organization or project.

How do I report such issues to ACBF?
ACBF has a secured e-mail to receive whistleblower complaints which is directly managed by the ACBF Head of Internal Audit Department. E-mail :  IAD@acbf-pact.org. This email address is being protected from spambots.

How does ACBF handle whistleblowers complaints?
In line with the ACBF Whistleblower Complaints Distribution Protocol, any reports received throughthe Whistleblower system shall be forwarded to:

1. The Chair of the Audit and Risk Committee (ARC) of the Executive Board if the complaint is on ACBF Board Members or the Executive Secretary.
2. Head of Internal Audit Department if the complaint is on ACBF management, ACBF staff members (excluding internal audit staff) and ACBF employed consultants.
3. The Chair of the ARC if the complaint is on ACBF Internal audit staff, including the Head of the Department.
4. Head of Internal Audit Department if the complaint is on ACBF grantees, sub grantees, affiliates as well as their management and staff.

The ACBF Executive Secretary is notified about the reported incidences on ACBF management, ACBFstaff as well as ACBF grantees, sub grantees, and affiliates.

Who investigates the issues raised through the whistleblower system?

The whistleblower reports are investigated by the ACBF Internal Audit Department (IAD). In order to maintain organizational independence and guarantee objectivity in performing its work, the Internal Audit Department reports directly to the Audit and Risk Committee (ARC) of the Executive Board and administratively to the ACBF Executive Secretary.

Depending on the gravity and the complexity of the case reported and the decision of the Audit and Risk Committee, investigation may also be conducted by an independent consultant/investigator.

What are the procedures followed when investigating a whistleblower complaint?

Once a report is received through the system, it is forwarded within 48 hours of receipt to either the chair of ARC or the Head Internal Audit Department. Thereafter:

1. A notification is sent to the whistleblower acknowledging receipt of the report.
2. The case is analyzed to determine if it is within the ACBF mandate. If not, the case may be shared with a relevant outside organization and a notification is sent to the whistleblower.
3. If the case is within the ACBF mandate, a preliminary assessment is undertaken to determine whether there is sufficient basis to warrant a full investigation.
4. Following the necessary investigation through desk review and/or fieldwork, a report is submitted to the Audit and Risk Committee of the Executive Board and the Executive Secretary.
5. The summary of the outcome of the investigation is also shared with whistle blower.
6. If the corruption, fraud or maladministration is substantiated, ACBF will invoke the necessary sanctions in line with the rules, regulations and procedures of the Foundation.

What is the protection for the whistleblower from retaliation?
ACBF Internal Audit Department and other concerned parties shall guarantee confidentiality and protection of the identity of the whistleblower, unless there is any legal requirement to disclose.

Where ACBF personnel, being a whistleblower, has suffered from retaliation or is threatened with retaliation because of the whistle blowing, he/she should contact the Head of Internal Audit Department with all information and document available. Depending on the gravity of the case, the Executive Secretary may notify the Executive Board of the circumstances and action taken to protect the whistleblower.

ACBF shall also commit to guarantee the protection of whistleblowers other than ACBF personnel. However, the protection ACBF can provide to external parties shall be limited to its capabilities.