ANTI-BRIBERY POLICY & MONEY LAUNDERING POLICY

HELPING HANDS FOR EDUCATION

(REGISTERED CHARITY NO. 1162358)

HHE has a zero-tolerance policy on bribery. We are a small charity with a narrow focus and thus have clear records of our income and expenditure. However, we have carried out a risk assessment and identified the following risk factors:

  • External factors: sending money overseas, to a region with higher potential for corruption

  • Internal factors: dependency on a partner organisation to carry out the mission statement of the charity

Our work in Nigeria is carried out through “The Alawiye Foundation”, an independent partner charity set up to facilitate the building of the education centre. This organisation is registered with the Special Control Unit Against Money Laundering and the Corporate Affairs Commission in Nigeria.

We have identified a number of ways in which bribery could potentially come into play and have thus addressed these issues in the following manner:

  • Facilitation payments

    • Facilitation payments from both personal and charity funds are strictly prohibited by HHE. Any member of HHE who is asked to make a facilitation payment should log the incident and report it to the board of trustees, who should then review the incident and decide what action to take.

  • Gifts and Hospitality

    • HHE does not currently permit the giving of gifts or payment of hospitality expenses with charity money in return for donations or services.

  • Purchasing and contracting

    • As per our mission statement once we raise enough funds HHE will transfer money to The Alawiye Foundation so building work for the education centre in Ogbomosho, Nigeria can be resumed. All funds transferred to Nigeria will be done via bank transfer to The Alawiye Foundation directly; no cash exchanges or transfer to individuals is permitted. HHE requires a full copy of all contracts and invoicing produced with any construction companies employed by The Alawiye Foundation to ensure funds are used transparently. Any company dealt with by either organisation should be made aware of our zero-tolerance policy on bribery.

    • Once construction resumes HHE will liaise regularly with The Alawiye Foundation for progress and expense reports to create a detailed record of how funds are being used.

  • Fundraising

    • HHE relies on fundraising and donations to work towards its mission statement. Records shall be kept of all income, with identification of donors where possible. Every effort shall be made to trace the origins of large donations.