Anti-corruption action plan

2018-2019

February 2018

I. Introduction

This document addresses the planned implementation of anti-corruption measures for the period 2018-19 and the action plan shall contain measures that both prevent and possibly reveal corruption and fraud/misuse[i]. This document will be used actively in the development of annual plans for the Atlas Alliance secretariat and organisations for 2018-2019. We attach the utmost importance to operationalising a common platform for professional development and awareness raising, and linking these efforts with closer dialogue and improved internal control procedures.Principles for Preventing and Managing Corruption specifies the roles and responsibilities at different levels in carrying out the plan.

By having a well-developed system for incident reporting, continuouslyassessing risks and vulnerabilities, and conducting regularspot-checks, we want to send an even clearer signal to employees at all levelsthat they can be controlled.The threshold to abuse power will thus be raised considerably. Secondly, we will be able to uncover old cases and expose newattempts of corruption and misuse. Thirdly, we willstrengthen the organisational culture at home and abroad, thus protecting and promoting the common values ​​we work for.

The plan will be revised in December 2018.

The action plan contains the following components:

  1. Introduction
  2. Strategic goals
  3. Action plan
  4. Roles and responsibilities
  5. Background documents

II.Strategic goals

  1. Main goals
  2. Prevention of corruption and fraud
  3. Effective and efficient assistance to the partners and their target

groups

  1. Organisational goals
  2. Close links between financial management and program

management

2.2.Systematic documentation and evaluation of all relevant

activities

2.3.Support and learning within the alliance

2.4.Systematic follow-up of anti-corruption policy and guidelines

2.5.Regular assessments of risks and vulnerability

2.6.Joint anti-corruption efforts with other organisation and donors

III. Action plan

2.1.Close links between financial management and program

management

The Atlas Alliance recognises the need for strengthening the ties between financial management and program management by:

  • Revising the Principles for Preventing and Managing Corruption.

-1st revision approved by board in March 2018

-2nd revision approved by the board in March 2019.

  • Appointing one of the program advisors in the secretariat as the responsible anti-corruption advisor.

-Rune Hjalmar Espeland is respohnsible until Marte Svare returns in August 2018.

  • Providing new and returning program advisors in the organisations with an introduction to the alliance's common guidelines, procedures and plans.

2.2.Systematic documentation and evaluation of all relevant

activities

The Atlas Alliance has an internal incident reporting procedure in place related to suspicions of unethical or illegal conduct. This is voluntary and requires a high degree of confidence in the proper follow-up and anonymity of our site. To be effective, voluntary incident reporting and internal control must be more strongly integrated into the secretariat's operations and incorporated into the organisation's project work in a way that is robust and of high quality. Such an integration will provide the secretariat and organisations with the assurance that we are in charge of anti-corruption efforts to comply with applicable laws and regulations and performed with the quality Norad expects by:

  • Seeking external advice to strengthen the secretariat's support function in anti-corruption work.
  • Strengthening the incident reporting procedures and follow-up measures

-Principles for Preventing and Managing Corruption revised by March 2018.

2.3Support and learning within the alliance

Good internal cooperation based on a balance between trust and control improves the ability of the Atlas Alliance to master the challenges facing our operations and minimises the risk of corruption. We want to achieve this by:

  • Organizing an anti-corruption trainings for program advisors and controllers

-1 workshop with an external consultant during spring 2018.

2.4Systematic follow-up of anti-corruption policy and guidelines

Having a formalized and well-functioning internal control system reduces the likelihood of arbitrary and conscious actions that lead to corruption by:

-Delivering an annual report to the board with an overview of

status, progress and measures.

-1 annual report produced for 2018 and 2019.

  • Developing and operationalising common guidelines and standards for per diem and allowances for all partners, adjusted by country.

-Guideline approved by board in March 2018.

-Revised guidelines approved by board in March 2019.

  • Conduct regular spot-checks of the partners.

-1 secretariat led spot-check per focus country in 2018 and the same for 2019.

2.5Regular assessments of risks and vulnerability

An important function of a risk and vulnerability assessments is to reduce the risk of corruption and identify what should be prioritised in the anti-corruption work. We will strengthen our assessments of risks and vulnerability by:

  • Integrating an assessment into the overall country analyses of the Atlas Alliance's main partner countries and taking advantage of the findings of the Social Audit Pilot Study in Nepal.

-1 report for each of the partner countries, Malawi, Uganda, Zambia and Nepal by June 2018.

-1 Social audit report for Nepal.

  • Asking partners for annual overviews of their project portfolio and other donors.

-1 report for 2018 produced in connection with annual reporting.

  • Considering toask partners for consolidated total accounts.
  • Obtaining, developing and operationalising common organisational due diligence assessment tools on corruption for the secretariat and organisations.

-Tools in place by August 2018.

-1 pilot assessment carried out by the secretariat in August 2018

2.6Joint anti-corruption efforts with other organisation and

donors

A number of donors and civil society organisations have joint efforts, internationally and at country level, which increases the added value of anti-corruption efforts. We would like to initiate and joins such efforts by:

  • Participating actively in the Norwegian anti-corruption group where civil society organizations in Norway gather to share experiences in anti-corruption work.
  • Introducing anti-corruption as a cross-cutting issue in existing country networks in Norway.

-1 gathering on anti-corruption in each of thecountry networks groups during 2018-2019.

  • Establishing new anti-corruption collaborations with donor organisations at country or regional level. Examples:

-Routines for common information sharing among donors to the same organisation/project on financial support and upon suspicion of misconduct.

-Annual meetings between donors to the same organisation.

  1. Background documents
  1. General document
  2. Forvaltningsloven
  3. Reglement for økonomistyring i staten
  4. Norad:
  5. Grant Scheme Rules for Support to Civil Society and Democratisation
  6. Ethical guidelines
  7. Retningslinjer for Norads håndtering av mistanke om økonomiske misligheter
  8. Norads varslingsplakat
  9. Norwegian Ministry of Foreign Affairs:
  10. How the Ministry of Foreign Affairs deals with financial irregularities
  11. Retningslinjer for håndtering av mistanke om økonomiske misligheter
  12. Atlas Alliance’s contract with Norad
  13. Atlas Alliance’s guiding documents:
  14. Principles for Preventing and Managing Corruption
  15. Manual in Financial Management and Internal Control Checklist for the Atlas Alliance
  16. Prinsipper og retningslinjer for bruk av midler (Februar 2016)
  17. Felles retningslinjer på per diem og allowances på lokalt plan hos prosjekt implementerende partner
  18. Code of Conduct
  19. Atlas-alliansens struktur roller og mandat
  1. Other:
  2. United Nations Convention against Corruption

Atlas Alliance –Anti-Corruption Action Plan 2018-2019Page 1

[i]The term “corruption” encompassesbribery, embezzlement, theft, fraud, extortion, misappropriation of public funds or others’ funds, favouritism/nepotism and the abuse of power for private benefit. “Corruption” encompasses any interaction between volunteer or public stakeholders whereby in an illegitimate or dishonest way public goods are illegally converted into private benefits(cfthe Norwegian Agency for Development Cooperation (Norad) definition of corruption). The Atlas Alliance emphasises that corruption is not limited to financial irregularities but also extends to sexual harassment and other forms of abuse of power.