Anti-Fraud Policy & Guidelines for Investigations

Conservation International takes a zero-tolerance approach to fraud, bribery, and corruption and will uphold all applicable laws relevant to countering and investigating such activities across its global operations.

CI is committed to:

• developing an anti-fraud culture across the organization
• seeking to minimize 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.

• The aim of CI’s Anti-Fraud Policy is to: set out CI’s responsibilities in observing and upholding its policy on fraud;
• provide information and guidance to Foundation employees and partners, grant recipients and their associates on how to recognize and deal with fraud issues; and
• establish standards of conduct for Foundation employees and partners, grant recipients and their associates so as to ensure that the relevant legislation is not violated.

CI’s Anti-fraud policy applies to all staff members, CI contractors, experts, consultants and grantees. It is an integral part of CI’s internal control policy framework and should be read and applied in conjunction with CI’s Code of Ethics. It forms part of a series of related policies and procedures developed to provide sound internal financial controls and to counter any fraudulent activity. These include: codes of conduct for staff and trustees; anti-corruption and bribery policy; sanctions policy; safeguarding policy; privacy policies; sound internal control systems; effective internal audit; effective recruitment and selection procedures; disciplinary procedure; public interest disclosure (whistleblowing) procedures; and training.

Reporting Fraud

CI has established an ‘Ethics Hotline’ to ensure that persons can report fraud. Anyone with information regarding fraud or other corrupt practices against CI or involving CI staff, non-staff personnel, vendors, implementing partners and responsible parties, is strongly encouraged to report this information through the Hotline and will not be retaliated against for submitting such claim in good faith. The Investigations Hotline is managed by an independent service provider on behalf of CI to protect confidentiality, and can be directly accessed worldwide in different ways:

Alternatively, complaints can be sent directly to CI by emailing ethics@conservation.org or by mail to:

Senior Director of Risk Management & Compliance
General Counsel’s Office (GCO)
Conservation International
2011 Crystal Drive, Suite #600
Arlington, VA 22202

All allegations of fraud and corruption are taken seriously. Upon receipt of an allegation, CI will assess the case and to determine if there is sufficient ground to warrant an investigation. Investigations will follow the guidelines outlined below.

Investigating Fraud

Depending on the nature, magnitude and the complexity of the fraud, investigations will be carried out by either CI’s General Counsel or by an external firm with specific expertise to deal with the particular allegation.

Investigations will be conducted without regard to any person’s relationship to the organization, position or length of service. The investigating party will have full access to any files, information or witnesses to conduct the investigation and will keep records of all actions in the investigation, to ensure success in any future criminal, civil or disciplinary action.

The investigating party will issue a report detailing the finding and conclusion of the investigation, including recommendations for future action. The report will be disseminated to and reviewed by CI's Senior Leadership and Audit Committee in a timely manner. Unless earlier notice is required by the donor, CI will inform other parties, including affected employees, external partners and donors of the conclusion of the report as needed.

In cases of substantiated fraud, CI will pursue disciplinary or criminal sanctions where appropriate and possible and will attempt to recover losses by any lawful means.