POLICY

Anti-corruption policy

How to stay on the safe side

Synaps adopts a zero-tolerance approach to corruption in all its forms. We cannot always prevent corruption, which is commonly found in many of the environments in which we operate. However, we will always raise, consider, and tackle any potential cases of corruption that arise in the context of our work, in line with this policy. Our approach applies to our own staff as much as to organizations we work with, including funding partners, implementing partners, peers with whom we collaborate on an informal basis, suppliers, and auditing firms.

Corruption is widespread, not least because the concept is poorly understood. People tend to equate corruption with its most explicitly illegal forms, such as intentionally diverting funds to one’s personal benefit. However, corruption describes a vast array of behaviors, some of which are commonplace, overlooked, and wrongly perceived as benign.

This policy aims to clarify exactly what we mean by corruption, to ensure that all our staff comply with our commitment to zero-tolerance. Rather than exhaustively list all possible forms of corruption, it describes those that particularly concern an organization of our kind. It specifies the measures we take to reduce such risks. And it lays out the process through which we will deal with reported cases.

Corruption

Corruption involves the abuse of one’s position for personal gain, whether monetary or otherwise, at the expense of others. For example, a member of staff may seek reimbursement for unjustified travel expenses, draining their organization’s resources without adding any value to its work. Corruption often implies a degree of power or authority, by which a person can force others to be complicit in corrupt practices, as in demanding bribes to facilitate paperwork.

Fraud

Fraud implies an element of deceit. This might involve falsified documents, such as made-up invoices. Deceit also includes intentionally misleading others through a lack of transparency. Accounts, for example, might be made difficult to read in order to obscure financial problems or the misuse of funds.

Double-dipping

Double-dipping is an expression used to describe a kind of fraud in which an organization invoices the exact same work twice. Notably, this happens when activities are funded by different donors who are unaware that they are paying for the same thing.

Embezzlement

Embezzlement describes a situation in which a member of staff steals resources belonging to their organization. Such resources may be funds or assets. The latter may be either tangible (eg a computer or a book) or intangible (eg a valuable idea or a dataset). Another word for embezzlement is misappropriation.

Conflict of interest

A conflict of interest is a situation in which personal interests entice a person to make decisions that go against the interests of the organization for which they work, including as a consultant, advisor, or board member. Even if the conflicted party refrains from prioritizing their own interests, the concept identifies the potential for doing so.

Bribery

Bribery occurs when a person tries to influence the behavior of someone in a position of authority by giving them money, gifts, services, or favors. Expensive “goodies” handed out at a conference, excessive hospitality, or consulting fees paid for desultory work can all be considered bribery. Bribes given to civil servants in exchange for them expediting bureaucratic processes are also called facilitation payments.

Kickbacks

Kickbacks are a type of bribery that happens when a person offers goods to others in return for granting them a contract. Such goods can take the form of money, free services, employment, or the promise of such benefits in the future.

Money laundering

Money laundering is a process designed to transform illegally acquired funds, typically in cash or cryptocurrencies, into legal resources. Such illegal funds may serve to cover operating expenses (like renting premises), to pay people (staff or contractors), or to buy assets (such as equipment), which then contribute to legitimate revenue-generating activities.

Nepotism

Nepotism describes the kind of favoritism in which someone redirects resources toward relatives and friends, providing them with jobs, business, or other benefits, in the absence of a fair, transparent, and competitive process.

In addition to the above forms of corruption, some of the concepts central to fighting corruption also need clarifying.

Internal controls

Internal controls are the policies and procedures an organization implements to prevent all forms of mismanagement. Internal controls must also reduce inefficiencies, rather than add to them: Policies and procedures that are unjustified or inefficient must themselves be amended or removed.

Procurement

Procurement is the process an organization follows to purchase goods or commission services, in ways that are justified, ethical, documented, transparent, cost-effective, and timely. Synaps implements the rules that are set out in its procurement policy.

Segregation of duties

Segregation of duties entails tasking different people with complementary roles in key internal procedures, to reduce the scope for corruption as well as errors more generally. Put into practice, this means the same person should not be able to request a purchase, approve it, and see it through. Likewise, significant transactions must be authorized through the signatures of at least two colleagues.

Due diligence

Due diligence means inquiring about a partner, a supplier, or a project to make sure they meet our legal obligations as well as our ethical standards.

Compliance

Compliance means adhering to all the legal obligations and ethical standards that apply to an organization. The term covers all the measures taken to achieve this result. Synaps follows the measures described in our compliance policy.

Audit

Audit is a review of an organization’s financial records, internal controls, and operational activities to ensure that they comply with its legal obligations, ethical standards, and contractual commitments. Audits may be performed internally or conducted by a third party. They are restricted in scope, pursue specific goals, and follow a systematic procedure, all of which must be transparently established at the outset. They produce a set of observations and recommendations on what the organization must improve moving forward.

Whistleblowing

Whistleblowing is the act of formally reporting misconduct on the part of an organization’s staff member, either to the organization’s management or to external parties, such as local authorities or the media.

Risk assessment

To reduce the risks of corruption, it is essential to be honest about it. Corruption can creep into any organization: People may treat some of its manifestations as trivial, find justifications for them, or slowly grow inured to corrupt practices, regardless of their initial best intentions. Therefore, Synaps is particularly vigilant when it comes to the following risks:

• Corruption of the more insidious kinds, such as unjustified travel expenses and participation in projects that disburse resources in ways that will not achieve the stated goals
• Fraudulent reporting, in the form of falsified budgets, inflated expenses, or unfair procurement procedures, not least prearranged bidding
• Double-dipping, for instance by asking different funding partners to pay for the exact same activities
• Embezzlement, through a staff member’s appropriation of Synaps’ assets, notably digital devices that they use in their work as well as reference books purchased by Synaps for its library
• Bribery, mostly in the sense of making facilitation payments, accepting undue gifts, and submitting to excessive hospitality
• Kickbacks, in the event a funding partner requests non-budgeted services or employment favors in exchange for signing a contract
• Money laundering on the part of organizations we work with or in the context of significant payments in cash
• Nepotism, if we hire or commission relatives or friends, or otherwise use Synaps’ resources to benefit them, because of who they are rather than what they contribute to our work

Another realistic risk is that staff members refrain from reporting corruption because of the circumstances surrounding their work. For example, their salary may depend on the continuation of a patently wasteful project. Legalizing their professional status may require paying bribes. And reporting a corrupt auditor may create more trouble than an organization wants.

However, Synaps’ zero-tolerance approach means that we must raise, consider, and appropriately tackle any such cases as they arise. When in doubt, don’t turn a blind eye or put off difficult discussions. Instead, raise your concerns openly, so that together we arrive at solutions that conform with this policy.

Internal controls

Synaps believes that fighting corruption is at least as much about institutional culture and work ethics as it is a matter of policies and procedures. The latter are nonetheless essential, not least because they help shape our culture and ethics.

Ethical financial management

Synaps builds ethical considerations into its financial management from start to finish.

• Our fundraising efforts are governed by our partnership policy, which sets the terms for what kind of relationships we are willing to engage in.
• Our budgeting follows a transparent and rigorous process that is entirely results-driven: We break contractual commitments down into detailed tasks, assign work packages to staff, and apply a fixed rate to each person involved.
• Any external services we commission fall under our procurement policy and our compliance policy.
• Our accounting implements best practices, notably segregation of duties, dual signatures, and full digitization.
• Our reporting procedures are systematized through our monitoring & evaluation policy.
• Finally, we perform as often as possible audits of different types, including project-based, thematically focused, and organization-wide.

Training and awareness

This policy is at the heart of our awareness-raising efforts. It is written to provide staff with a clear sense of what corruption is and how it concerns us all. New hires read this policy and are quizzed on its key components as part of their onboarding.

That said, awareness grows best through frequent internal conversations around concrete problems, as they arise. We openly discuss the forms of state corruption we are exposed to, the cases of money laundering we uncover through our fieldwork, the dubious practices we observe within the aid and development sector, and so forth. Considering such examples serves to reinforce our staff’s practical understanding of this policy.

Whistleblowing and follow-through

Corruption must be reported via our complaints policy, which lays out secure and efficient communication channels, investigation procedures, and decision-making mechanisms. Proven cases of corruption may lead to the dismissal of staff, ending a partnership, or escalation through the relevant authorities.