Fraud protocol and anti-corruption policy


Fraud has many forms of appearance. However, its essence is always the same: people (or organisations) appropriate money or assets to which they are not entitled and thereby affect the rights of others. They do this by, for example, not carrying out projects but declaring that they have been implemented, by increasing costs when those costs have not been incurred or not to transfer money intended for the Christian Childcare Programme of The Netherlands Foundation (further: CCP) to CCP. As a result, they disadvantage CCP in its goals. The concept of fraud as such is not defined in the Penal Code. However, these are cases commonly referred to as fraud, which can be used to include forgery, fraud, deception, corruption, theft and/or embezzlement.

(Biblical vision) of fraud

Being good stewards is a costly task as members of CCP. We have resources at our disposal to implement our objectives. Fraud is therefore far more far-reaching than the misuse of resources. It not only shames the trust of our donors, but also damages the image we give as part of the kingdom of God.

Global internal control description

The CCP administration is controlled by at least one external and one board member, not the Treasurer. They monitor the work of CCP administrators once a year. The internal procedure regarding payments is split in two steps.1) The invoice is checked and submitted through one of the members of the executive board.2) The processing of the invoice, second pairs of eyes and the payment is made by a CCP financial officer.

How to act on suspicion of fraud

An internal investigation will begin on suspicion of fraud. The underlying documents are requested and reviewed. An external auditor is involved if necessary. Of all the steps that are taken, the board reports to the meeting of the general and executive board..

Hotline for example, a board or confidant

As a policy, the board is designated as a hotline. Fraud can be reported to one or more board members.

Disciplinary action against those involved

If fraud is detected, the board shall determine the final response and measure. If fraud is detected, at least one reprimand will follow. Punishable facts are reported to the police. In addition, CCP will recover the embezzled amount plus costs incurred from the fraudulent party

Reporting to donors, communication in case of fraud detected

If there is fraud, this will be reported by means of a letter to the supporters/donors. This is also reported in the annual report.

Familiarity with the board and grassroots

The fraud protocol is published on the CCP website. In addition, the fraud protocol is sent to all CCP board members.

The partner organisation in Uganda, CCP Uganda

CCP Uganda is an independent organisation, which has not been controlled by the Dutch government since January 2018. In order to prevent and combat possible fraud and corruption in the South, the following measures have been taken:

  • CCP Uganda is governed by an unpaid local government made up of people from different ethnic groups, churches and professions. The staff is accountable to the board.
  • Cash recordings can only be done by signature of a staff member and a board member.
  • The annual accounts are audited and approved annually by a professional external auditor.
  • At least once a year a visit takes place by a representative of the Dutch board to evaluate all projects and to monitor the use of the funds with their own eyes.

Anti-corruption policy

HThe board or employees of the CCP board will not participate in bribery, either directly or through a third party. Inappropriate payments are never made. We never try to induce a person or local/foreign official to act illegally or inappropriately. CCP never offers, or never gives, a gift or token of hospitality to a public employee, government official or representative when there is any expectation or implication for a return favor, and we never accept a gift from a relationship when there is any suggestion that a return favor is expected or implied. We will never incite or assist another person to violate any applicable law or law.

26 september 2019