Ethics, Compliance, and Safeguarding

IWPR has a zero-tolerance policy towards fraud, bribery and corruption. We will always investigate and seek to take disciplinary and/or legal action against those who commit, attempt to commit, or assist anyone committing fraud or any other improper activities in our operations. Individuals must not seek advantage by giving or accepting any gifts, entertainment, or payments that may be perceived as inappropriate.

IWPR is committed to:

• Developing an anti-bribery culture across the organisation.
• Seeking to minimise the opportunities for fraud, bribery and corruption.
• Having effective systems, procedures, and controls in place to enable the prevention and detection of fraud, corruption and bribery.
• Ensuring that its staff are aware of the risks of fraud, bribery and corruption and understand their obligations to report any actual or suspected incidents of fraud, bribery or corruption.
• Taking all reports of fraud, bribery and corruption seriously, and investigating them proportionately and appropriately.
• Meeting its obligations to report any incidents of fraud, bribery and corruption to appropriate external authorities.

IWPR aims to create a safe environment in which no child (individuals under the age of 18) or adult will experience harm or exploitation during their contact with us or as a result of our programming. IWPR maintains a zero-tolerance approach to any form of sexual abuse, exploitation, harassment, or neglect.

IWPR is committed to:

• Complying with relevant laws and standards and ensuring local legal compliance.
• Minimising and managing situations where abuse could occur. This will be done through maintaining strong protection systems and procedures including planning, risk assessment and safeguarding systems.
• Sharing safeguarding best practice and information regarding safeguarding concerns with relevant parties, maintaining confidentiality so far as possible.
• Taking action and investigating suspected abuse proportionately and appropriately.

Activities that conflict with the interests of IWPR must be avoided and individuals must not use their position within IWPR for personal advantage or gain. This includes personal relationships and outside business interests or employment.

IWPR is committed to ensuring:

• That individuals do not use their position at IWPR for personal advantage or gain.
• Conduct at work is not adversely affected by close personal relationships whether with colleagues, consultants, suppliers, implementing partners or others with whom we work with.
• Individuals declare any conflict of interest or personal relationship (including working with family members).

IWPR supports a zero-tolerance policy to combat human trafficking and forced labour (Modern Day Slavery). We are committed to high standards of ethics and integrity and comply with international laws prohibiting actions that facilitate trafficking in persons and modern-day slavery.

IWPR aims to ensure that no exploitation or breach of either Trafficking in Persons or Modern-Day Slavery legislation occurs. Steps to ensure compliance include:

• Confirming the identities of staff and their right to work legally in their country of employment. Including assurances that such checks have been obtained for agency staff, which safeguard against human trafficking.
• Vetting of staff and suppliers and partners.
• Ensuring suppliers are carefully selected through robust procurement processes.
• Following local labour law and ensuring a non-discriminatory and respectful working environment for all staff.

IWPR is committed to ensuring that there is no unjustified discrimination within its operations on the basis of age, disability, gender including transgender, HIV/AIDS status, marital status including civil partnerships, pregnancy and maternity, political opinion, race/ethnicity, religion and belief, sexual orientation, socio-economic background, work pattern, having or not having dependents, or on any other grounds which are irrelevant to decision making.

We will treat individuals with fairness, dignity, and respect. We aim to abide by and promote equality legislation and try to avoid unjustified discrimination which we recognise is a barrier to equality, diversity, inclusion, and human rights.

All IWPR staff/consultants and those writing on behalf of IWPR are expected to always follow to the NUJ’s code of conduct. It is used by journalists to challenge unethical instructions and produce content that is "honestly conveyed, accurate and fair":

• At all times upholds and defends the principle of media freedom, the right of freedom of expression and the right of the public to be informed.
• Strives to ensure that information disseminated is honestly conveyed, accurate and fair.
• Does her/his utmost to correct harmful inaccuracies.
• Differentiates between fact and opinion.
• Obtains material by honest, straightforward and open means, with the exception of investigations that are both overwhelmingly in the public interest and which involve evidence that cannot be obtained by straightforward means.
• Does nothing to intrude into anybody’s private life, grief or distress unless justified by overriding
• consideration of the public interest.
• Protects the identity of sources who supply information in confidence and material gathered in the course of her/his work.
• Resists threats or any other inducements to influence, distort or suppress information and takes no unfair personal advantage of information gained in the course of her/his duties before the information is public knowledge.
• Produces no material likely to lead to hatred or discrimination on the grounds of a person’s age, gender, race, colour, creed, legal status, disability, marital status, or sexual orientation.
• Does not by way of statement, voice or appearance endorse by advertisement any commercial product or service save for the promotion of her/his own work or of the medium by which she/he is employed.
• A journalist shall normally seek the consent of an appropriate adult when interviewing or photographing a child for a story about her/his welfare.
• Avoids plagiarism.

IWPR is committed to protecting the confidentiality, integrity, availability, and resilience of the information it collects, stores, transfers and processes in accordance with UK law and international good practice, and to meeting its legal requirements and contractual obligations.

Individuals are expected to safeguard data and information privacy and should access, use, share, transfer and retain any data or information only for legitimate business purposes and in a secure manner, ensuring all confidential information is encrypted and/or password protected.

Users of IWPR IT resources, including email, must use them in a responsible and legal manner.

IWPR is committed to maintaining the highest standards of ethical conduct, integrity, and accountability in all aspects of its operations. Accordingly, IWPR expects anyone acting on our behalf to do the same and our expectations are set out in the Global Code of Conduct.

Anyone becoming aware of conduct on the part of any IWPR staff member, beneficiary, partner or associated third party that may undermine IWPR’s financial integrity, or cause the harm to or mistreatment of any individual/s, or jeopardise the proper performance of its mission, should report it promptly.

The below provides examples of the types of misconduct or behaviour that could give rise to a report; however, it is not an exhaustive list and IWPR encourages individuals to report any behaviour or incidents which they have concerns about.

• Criminal activity or offences, including fraud, theft, and embezzlement.
• Corruption, bribery or blackmail.
• Financial malpractice, impropriety or mismanagement, facilitating tax evasion.
• Sexual exploitation and abuse, sexual harassment (SEAH) and child abuse and neglect.
• Gross mismanagement or waste of a US Federal contract or grant.
• Failure to comply with any legal or professional obligation or regulatory requirements.
• Conduct likely to damage IWPR’s reputation or financial wellbeing.
• Actions which endanger the health and safety of IWPR’s personnel, partners or the public.
• Actions which cause damage to the environment.
• The deliberate provision of false information to public officers.
• A miscarriage of justice.
• Unauthorised disclosure of confidential information.
• The deliberate concealment of information relating to any of the above matters.
• Retaliation against someone for speaking up or “whistleblowing”.

Staff of IWPR and IWPR’s subrecipients have certain whistleblower rights and protections under 41 U.S.C. 4712. Staff who make a protected disclosure about a US Federal grant or contract cannot be discharged, demoted, or otherwise discriminated against as a reprisal for disclosing to a person or body information that the employee reasonably believes is evidence of gross mismanagement of a Federal contract or grant, a gross waste of Federal funds, an abuse of authority relating to a Federal contract or grant, a substantial and specific danger to public health or safety, or a violation of law, rule, or regulation related to a Federal contract.

IWPR’s employees, partners, clients, beneficiaries, and other individuals should report observed or suspected misconduct to IWPR’s anonymous online form or by emailing: raisingconcerns@iwpr.net. IWPR takes all allegations seriously and will investigate all concerns raised in good faith. 

For additional information or questions about IWPR’s Whistleblowing Policy, or to obtain a copy of the full policy please contact compliance@iwpr.net.