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Anti-Corruption Policy

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Activities, Manuals, Protection, STRATEGY, Updates,

Emma Organization for Human Development

General information
Corruption is one of the most main obstacles to development in many countries around the world. The
UN Convention against corruption states:
“Corruption undermines democratic institutions, retards economic development and contributes to
government instability. Corruption attacks the foundation of democratic institutions by distorting
electoral processes, perverting the rule of law, and creating bureaucratic quagmires whose only reason
for existence is the soliciting of bribes.
Economic development is stunted because outside direct investment is discouraged and small
businesses within the country often find it impossible to overcome the “start−up costs” required
because of corruption. ”
Emma organization for Human Development (EMMA) will work actively towards the prevention and
detection of corruption and that Emma expect all employees to strictly adhere to the policy and
established procedures. EMMA disapproves of all forms of corruption and has through the adoption of
this policy, taken a Zero− Tolerance position towards it. EMMA believes that a strong emphasis on
anti−corruption and transparency will strengthen the reputation and trust towards our organization,
both from our donors, the general public, our cooperating partners and our employees.
Definition of Corruption:
EMMA acknowledges the fact that the definition of corruption differs widely in the different areas. What
might be considered corruption in one country might be considered as acceptable practice in others.
Everybody would probably agree that bribes, extortion and the practice of demanding sexual favors in
change of services, are highly unethical acts that must be termed as corruption. Other cases, such as
favoritism and nepotism, are however acceptable or almost acceptable in some cultures.
EMMA has chosen to adopt Transparency International’s definition of corruption, namely that
corruption is; “the abuse of entrusted power for private gain”.
Corruption occurs in many forms. The list below gives just a few examples:
 Bribery: When someone improperly provides goods or services against some form of improper
 Kickback: A form of bribery, where someone involved in a purchasing process is getting a reward
from the supplier for placing an order of goods or services.
 Embezzlement: Theft of resources for own use.
 Evidence destruction: Irregular destruction, removal or abuse of records.
 Extortion: The act of obtaining something by force, threats or undue demands.
 Favouritism: The unfair favoring of one person or a group at the expense of others (includes
nepotism, which is favouritism shown to relatives).
 Knowingly omitting to report corrupt acts: Deliberately omitting or refusing to report or act
upon reports of any such irregular or dishonest conduct.
 Maladministration: Maladministration or financial misconduct in handling or reporting of
money, financial Transactions or other assets.
Zero Tolerance Policy
EMMA has a Zero Tolerance attitude towards corruption. This means that EMMA disapproves of all
conduct that can be termed as anti-corruption. It also means that EMMA commits itself to follow up,
investigate and prosecute cases where corruption has been detected to the full extent within
established procedures, while always taking into consideration the severity of the case as well as local
EMMA will address corruption issues on a regular basis in various ways in order to ensure that EMMA
employees are aware of this Anti-Corruption policy and are motivated to abide by it. EMMA Director has
the responsibility to ensure that the policy is properly distributed and communicated in her
organization. Furthermore, it is the EMMA Director responsibility to ensure that the Anti-corruption
procedures and process descriptions found on the EMMA Quality Management System and fully
implemented and complied to.
Training and Awareness Raising
In addition to training and other means of awareness raising, EMMA’s employees will be made aware of
this Anti-Corruption Policy and the responsibilities it put on all EMMA employees on signing the Code of
Conduct. All employees must state their acknowledgement and compliance with the Code of Conduct in
writing. Managers should lead by example in preventing and avoiding corruption. All employees have a
duty to report cases of suspected corruption, following the reporting procedures for such cases.
Reporting can be done anonymously, without fear of retaliations.
Reporting & follow up of reported suspicion of Corruption
EMMA is fully committed to follow up all cases of reported suspicion of corrupt acts, and take
appropriate action when such reports actually leads to disclosure of corruption. The measures taken
against parties involved in corrupt acts, will always be measured against the severity of the case
disclosed, and will be done in compliance with local Laws and regulations as well as EMMA’s own
policies and procedures.
It is EMMA policy to protect the employees who report cases of suspected corruption (Whistle blowers).
Reports can be submitted anonymously if the whistleblower chooses to do so.
By signing the code of conduct all employees acknowledge that it is in fact a corrupt act not to report
such suspicions and all managers acknowledge that it is a corrupt act not to act upon such reports.
EMMA will establish a standard procedure for Alert Raising with a separate Check List. It is the EMMA l
Director responsibility to make sure these procedures and checklists are distributed and fully
implemented within her organization.
Risk Assessments
EMMA will include a corruption risk assessment in all relevant work processes. EMMA will strive to have
a sound knowledge and understanding of potential risk areas, and will incorporate risk assessments in
relevant documents such as organization strategies, work plans, project applications etc.

Emma Organization for Human Development was founded in 2013 by three female activists with a vision to advance the role of women in society, promote gender equality and empower women in Kurdistan. “Emma” is a Kurdish term meaning (WE) and is the concept by which this organization functions as a unit working together as "One Team" from different cultural backgrounds and religious beliefs to achieve goals and rebuild lives.

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