1. Handling money and materials with integrity: We use the money and materials we receive
from individual supporters and institutional back-donors as honestly, efficiently and
effectively as possible.
Fraud, theft, misuse of goods or services, and culpable waste includes the
acquisition or misuse of our funds or property by deception, which consists of but is
not limited to any intentional act or omission relating to (1) failure to disclose an
interest in order to enjoy financial or other benefits or gains, or cause a loss to a
person, project or organization in the process of distributing our funds, (2)
misapplication of our funds for purposes other than those agreed in the contractual
arrangement, and (3) use or presentation of false, incorrect or incomplete statements
or documents which has the effect of misapplying, misappropriating or wrongfully
retaining of funds and non-disclosure of information in violation of a specific
obligation with the aforementioned effect.
2. Handling power with integrity: We expect our staff, volunteers, partners, program
participants and allies to understand how power works and to handle power in their
relationships responsibly and with integrity. This means being especially careful when there is
power-disbalance in hierarchy in roles, financial power, age-,gender- health-, sexual or
lifestyle differences, possible (unconscious) power differentials in (colonial-) history, culture,
race, ethnicity etc. We expect doubts, conflicts of interests and confidentiality-questions to be
shared, so that these can be explored and solved, via moral deliberations.
Corruption includes abuse of entrusted power for private gain or private pleasure
based on financial and/or non-financial actions. This includes – among other things –
offering, seeking and/or accepting (personal) services, resources or any other
advantage by abuse of trusted power. Trusted power is abused by carrying out –
directly or indirectly – any unlawful acts, bribery, theft, embezzlement, extortion,
(personal) exploitation, or conflict of interests, fraud, granting or receiving unlawful
compensation, money laundering.
3. Interpersonal ntegrity: We expect our staff, volunteers, partners, program participants and
allies to be fully committed to our mission. We stand for our constitution: all persons shall be
treated equally in equal circumstances. This means we stand for justice. Therefore, we work
to achieve an organizational culture in which we respect diversity and achieve inclusion for
all
Interpersonal violations include any form of discriminatory expressions,
discrimination, intimidation, humiliation, bullying, violence, abuse towards children
and vulnerable adults, sexual harassment, sexual harassment and sexual violence
and any similar actions or inactions
Specifically: Bullying is when a person (child) is intimidated (verbally attacked, joked
about, humiliated, offended) excluded, or threatened. ‘Mobbing’ is if the event is
perpetuated by a group of individuals.
Discrimination: Any behavior/acts exercised by an individual or group which
promotes the unequal treatment on the grounds of race, ethnicity nationality,
gender, sexual or identity preferences, physical or mental health, age, religious, or
political convictions. (This can also occur systematically).
Sexual harassment:where a person (child) is sexually annoyed, intimidated,
humiliated, threatened, violated, or exploited by another. Thus, failing to respect
consent or physical and sexual integrity of another person.
It is a violation to dehumanize any child or person, or to infringe on their dignity by
our behavior. We will not tolerate that our staff, volunteers, partners, program
participants or allies engage of support any form of slavery, enforced- or childlabor,
or sexual exploitation or human trafficking. (A child is defined as someone under the
age of 18 regardless of the age of majority/consent in country).
4. Professional integrity: We expect our staff to work according to our agreed professional
values: to work towards concrete goals, to cooperate and share knowledge, to take personal
responsibility and leadership and promote trust in others. To be relevant, work ‘evidence
based’ and be known to be thorough and accessible. We can be flexible and cope with
(changing) priorities.
A Professional violation involves culpable behavior or negligence which results in
demonstrable and significant harm towards colleagues, partners or allies, or the
reputation of the Symi Network.
Failure to adhere to this code of conduct will lead to proportional punishment from disciplinary
measures up to terminating the contract with staff, partners and/or allies. The rest of this policy is
about prevention, and where staff and partners can find information and support to prevent, stop
and ALWAYS report integrity violations.
2. Preventing integrity violations
The Symi Network holds high standards of integrity, and we do a lot to prevent integrity violations.
Our CFO/COO will work to prevent, detect, and address such issues. Building relationships
between the Symi Network Foundation and the grantees and program participants, and gaining
knowledge of respective boundaries, rules and procedures, are also of instrumental value for
prevention.
2.1. Awareness
We create awareness of our code of conduct and contractual obligations with partners, volunteers,
program participants, members of the Supervisory Board and committees, and where relevant with
allies. We provide the necessary training and support to staff for the effective implementation of this
policy.
2.2. Risk management
We take precautions to mitigate the risks and consequences associated with our integrity policy and
practice. We do so through our due diligence research, risk assessment at the start of each grant or
project or collaboration and through our monitoring tools. Monitoring focuses on the on-going status
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of the project. Monitoring is an on-going process and must be done continuously. Monitoring of
grants and projects is done by reporting, audited reports, monitoring visits and evaluations.
2.3. Contracting (formal relations)
Each partner receiving financial support must be formally and legally bound to our organization by an
agreement. The agreement must contain an integrity- and anti-fraud and corruption clause and refer
to instructions for integrity- and financial control and reporting. The agreement must stipulate that
the other party or parties is/are responsible for their integrity management and control, as well as
for the implementation, monitoring and evaluation of the project. The agreement ensures that the
funds received are used efficiently for the purposes for which they have been granted. Last but not
least, the other party or parties must implement integrity policies for the full duration of the project,
and all of their employees must be aware of this policy. Additional conditions may be incorporated
into the agreement to mitigate risks based on the outcome of a due diligence investigation, risk
assessment or other indicators. All agreements are governed by Dutch law. In cases involving
integrity violations, however, both contract and criminal laws may apply, depending on the laws of
the country where integrity violations are revealed.
2.4. Moral learning
At all levels of our staff make decisions. Some are morally important, in terms of our mission and the
communities we work with, and the focus countries where we operate. Rights of those we work with
can be affected, their interest can be at stake. It is possible that our guiding principles and aspects of
our code of conduct can contradict each other. That is why we install the system of moral
deliberation and learning which will help staff explore important, difficult, and doubtful decisions.
This helps everyone in the organization to implement our mission, and code of conduct in a
consistent manner. During the deliberation all arguments around all those affected by a decision are
collected, and weighed. Then it becomes clear what is the morally right decision and which measures
can be taken to mitigate damage for some. This means the decision is morally right and so in
accordance with justice.
This leads to consensus in a particular case, and by recording these cases we can increase our moral
learning in a consistent manner: an archive or record of these moral deliberations will be the
moresprudence of the Symi Network. The collected moral learning for (new) staff, and the
explanation of moral decisions taken is important to partners and program participants, as well as,
where relevant, to back-donors.
3. Reporting integrity violations
Within the Symi-Network we prevent integrity violations, but it is not entirely possible to prevent
breaches from being made. Staff or partners/allies/participants who are victims or witnesses to
any integrity breaches or violations, are encouraged to report these to our designated independent
Integrity officer. Any such reports require preliminary investigation and appropriate action. The
contact details are: ………………
3.1 Complaints received by the Integrity Officer (from staff, managers, complainants, partners,
program participants or allies).
We encourage staff, volunteers, and program participants as well as allies to raise concerns about
possible violations to our Integrity reporting point:
A complaint can be submitted: by telephone via 088 xxxxxx (accessible Monday through Friday from
08.30 - 17.00) and/or by e-mail:………………….
Then:
1. The complaint will be assessed in accordance with the organization's complaints procedure,
including whether the nature of the complaint is admissible for consideration.
2. Information will be gathered on the complaint from both the complainant and the accused, to
determine if the complaint is found to be possible and credible, and indeed is an integrity
violation (according to our Code of Conduct).
3. The Integrity Officer will give advice to the Management Board about the results of the
preliminary assessment, and advice about further steps to be taken. If the issue concerns a
member of the Management Board, the advice will be given to the Supervisory Board. This
advice takes into account the wishes of the complainant/victim. The Management Board (or if
relevant the Supervisory board) will together decide what further steps of measures need to be
taken, including whether additional investigation is required.
Once we receive a concern through one of our reporting channels or as soon as someone in our
organization gets an indication that there could be an integrity breach or violation, a mandatory
protocol is followed. Our Investigation protocol consists of the following steps:
4.1 Phase 1: Decision whether investigation is needed
1. Once a concern is received or identified where-ever in the Symi Network, the integrity officer is
informed.
2. The integrity officer organizes a kick-start meeting. During this meeting the available information
is shared. The principle here is zero-tolerance for non-action.
3. The integrity officer (after hearing from the relevant parties) informs the Management Board
whether a Preliminary Assessment is needed. If the case involves private funding (private
donors, lotteries, and major donors) the Integrity officer also informs the Supervisory Board
throughout the implementation of the protocol.
4.2 Phase 2: Preliminary Assessment
4. The Integrity officer installs the investigative team with a clear assignment for the preliminary
investigation. The investigative team consists of expert(s) and the integrity officer. The team is
led by the integrity officer. The integrity officer adds the case to the Integrity register and opens a
Teams group where information is gathered and shared.
5. The investigative team gathers and analyses available information, including interviewing the
reporter/complainant and (if relevant) the accused.
6. The Integrity officer shares the outcomes of the preliminary investigation with the Management
Board and the designated member of the Supervisory Board, and gives advice about the further
steps to be taken. What these are depends on the kind and extent of the integrity breach or
violation, and on the rights and wishes of the complainant. They decide on the further process,
and inform the Supervisory Board.
4.3 Phase 3: Disciplinary investigation
7. A proposal for the disciplinary investigation (including process and budget) is developed by the
integrity officer in consultation with the investigative team. This needs approval from the
Management Board.
8. The Integrity officer will keep the Management Board informed how this process proceeds, who
in turn informs the Supervisory Board, as well as other relevant board and committees, and/or
donors depending on the project.
9. The integrity officer selects the appropriate (external) expert(s) to conduct the disciplinary
investigation. The integrity officer supervises the investigation, monitors the progress and
budget, assesses quality of work delivered and questions the investigators critically about
methodology and conclusions.
10. The integrity officer shares the findings of the disciplinary investigation with the internal
investigative team, the CFO/COO, and seeks (if relevant) external legal advice about proposed
disciplinary measures.
11. The integrity officer advises the Management Board about the outcomes of the investigation and
about the proposed measures. The Management Board decides on further steps and informs the
Supervisory Board.
4.4 Phase 4: Informing external stakeholders and taking measures
12. An integrity violation that has become known internally or to other organizations, stakeholders
or the press needs extra attention in communications. The Integrity officer seeks advice and
develops an internal and external communication strategy. This strategy takes into account the
(privacy) rights of the complainant and accused and describes how the organization is dealing
with the integrity violation, and which lessons are learned to prevent such violations.
13. The Management Board decides what disciplinary measures are to be taken based on the
findings, approves the communication strategy in case of a crisis and follows the reporting
procedure to the Supervisory Board.
14. The approved disciplinary measures are implemented. The process of implementation is led by
the Integrity Officer. For every step of the approach, it is essential to supervise (with relevant
managers) if the compliance to the conditions of the respective donor is strictly to the rule.
4.5 Phase 5: Document lessons learned
15. The Integrity Officer is responsible for documenting lessons learnt and if needed to propose
adjustments to our policy and procedure.
The SYMI NETWORK Fundraising policy
The overarching objective of the SYMI Network Foundation is:
- to promote democracy and good governance worldwide,
- to encourage societies to establish transparent-, just and impartial rule of law and
democratic principles,
- to thus safeguard universal human rights.
It is this overarching objective which forms the foundation of the SYMI NETWORK Fundraising policy.
The SYMI NETWORK will seek to build fundraising relationships with:
individuals, private foundations, and governmental donors,
who through their own mission, strategies, policies, and actions
CAN and DO underwrite the SYMI NETWORK overarching objective.
This means that the following Ethical Fundraising Guidelines apply:
1. Mutual Transparency and Accountability
The SYMI Network Foundation and any potential donor share information about:
- Their organizations, values, strategic goals and integrity policies.
- Detailed information about the precise purpose of funds given and how to be used.
- Agreements about the accountability responsibility, monitoring systems, and reporting
agreements. This specifically means ensuring that risks and responsibilities are ‘fit for
purpose’ and reasonable for both parties.
- Clarity about applicable laws and regulations related to fundraising, financial management,
data protection and reporting agreements relevant to ‘best practice’ in fundraising.
2. Mutual Loyalty and Respect
The SYMI Network Foundation and any potential donor will agree together on issues of:
- Privacy, right to information, acknowledgement of the funding relationship.
- Data and reporting transparency and areas of confidentiality.
- Integrity policies governing possible conflicts of interest, avoidance of coercion etc.
- Agreements on common communication strategies in situations of possible crisis-, conflict-,
and/or political or organizational pressures.
3. Responsible spending and reporting, within the real-time risks and pressures faced:
The SYMI Network Foundation and any potential donor will agree together on issues of:
- Responsible and reasonable spending on activities relevant to the shared program goals.
- Reasonable reporting on output- and outcome indicators of the work done, including on
longer-term impact indicators (in order to learn and improve agreed on strategies).
- Agreement on the level of shared risks taken by the donor and the SYMI Network, including
agreement on internal and external communication about problems, mitigation, and failures.
The SYMI Network Ethical Fundraising Guidelines described leads to fundraising efforts
with potential funding partners such as:
