Anti-Corruption, Anti-Bribery, Fraud & Whistleblower Policy

This Anti-Corruption, Anti-Bribery, Fraud, Conflict of Interest and Whistleblower Policy ('Policy') applies to Innovative and Equal (Նորարար ու Հավասար, MOJ: 211.171.1242074, 'the Organisation'), its Board of Directors, all employees, volunteers, interns, consultants, contractors, suppliers and implementing partners, without exception, and to every transaction, grant, procurement and programme activity conducted in Armenia or abroad in the Organisation's name.

The purpose of this Policy is to prevent, detect and respond to corruption, bribery, fraud, embezzlement, conflicts of interest and money laundering, to protect donor and public funds entrusted to the Organisation, to comply fully with the RA Law on Combating Corruption, the RA Law on Public Organisations, the RA Criminal Code provisions on bribery and abuse of authority, and applicable international anti-corruption instruments including the UN Convention against Corruption, and to safeguard the Organisation's integrity and the trust of the communities it serves.

Every person within scope must read, sign, and annually reaffirm acceptance of this Policy as a condition of continued engagement with the Organisation. Ignorance of this Policy is not a defence against disciplinary or legal consequences.

Bribery: offering, promising, giving, requesting or accepting anything of value to induce or reward improper performance of a duty, including cash, gifts, favours, employment offers or hospitality.

Facilitation payment: a small unofficial payment made to secure or expedite a routine government action to which the Organisation is already entitled, such as processing a permit. Facilitation payments are strictly prohibited, with no de minimis exception.

Kickback: a portion of a contract payment returned covertly to a decision-maker, procurement officer or intermediary in exchange for awarding or maintaining business.

Embezzlement: the misappropriation of Organisation funds, assets or property by a person to whom they have been entrusted.

Nepotism and cronyism: favouring relatives, close friends or personal associates in recruitment, procurement, grant-making or promotion decisions, in preference to more qualified or more competitive candidates.

Procurement fraud: manipulation of tenders, bid rigging, inflated invoicing, phantom vendors, or collusion between staff and suppliers to defraud the Organisation.

Money laundering and sanctions evasion: processing funds derived from criminal activity to disguise their origin, or transacting with individuals or entities subject to Armenian, EU, UN or US sanctions lists. All partners and major vendors are screened against publicly available sanctions lists before contracting.

Personnel may accept or offer only modest, occasional gifts or hospitality of a value not exceeding AMD 20,000 per instance and AMD 60,000 in aggregate from any single source per calendar year, provided the gift is not cash or a cash equivalent, is not solicited, and does not coincide with a pending procurement decision, grant award or contract renewal involving the giver.

Any gift or hospitality offered or received, regardless of value, that exceeds these thresholds, or that is declined, must be recorded within five business days in the Organisation's centrally maintained Gifts and Hospitality Register, which is reviewed quarterly by the Finance and Audit Committee and disclosed in summary form in the annual report.

Gifts to public officials, judges, police officers or government employees connected to the Organisation's regulatory or funding relationships are prohibited outright, with the sole exception of nominal promotional items of negligible value (such as branded stationery) distributed openly to entire delegations.

Procurement up to AMD 300,000 may be made by direct purchase against a single quotation, recorded on a purchase request form signed by the requesting manager and countersigned by Finance.

Procurement between AMD 300,001 and AMD 3,000,000 requires a minimum of three independent written quotations, a comparative bid analysis, and approval by the Finance Director; the lowest compliant bid is selected unless a documented, pre-approved exception applies (for example, sole-source availability, which must itself be justified in writing).

Procurement exceeding AMD 3,000,000 requires a formal open or restricted tender process, published internally and, where donor rules require, publicly, with a tender evaluation committee of at least three members none of whom has a conflict of interest with any bidder, written scoring criteria fixed before bids are opened, and Board or Executive Director sign-off on the award.

No procurement may be artificially split into smaller transactions to avoid a higher-threshold approval requirement; any such splitting discovered during audit will be treated as a Policy breach and investigated as potential fraud.

No single individual may initiate, approve and disburse the same payment. At minimum, the person requesting a payment, the person approving it, and the person executing the bank transfer must be three different individuals.

All bank payments above AMD 500,000 require dual signatures from among the Executive Director, Finance Director and Board Treasurer, and no signatory may authorise a payment to themselves, a relative, or an entity in which they hold an interest.

Bank reconciliations are performed monthly by a staff member independent of payment processing, and reviewed by the Finance and Audit Committee quarterly. An independent external audit of the Organisation's full accounts is conducted annually and the audit report, including any findings on internal controls, is presented to the Board and, where legally required, filed with the Ministry of Justice.

Funds restricted by a donor to a specific programme, budget line or geography must be tracked in segregated ledger codes and may never be reallocated to another purpose without the donor's prior written consent. Any deviation is reported to the donor within 10 business days of discovery.

Grant-funded procurement must additionally comply with the specific donor's procurement rules where these are stricter than the Organisation's own thresholds, and Finance maintains a matrix mapping each active grant to its applicable donor-specific compliance requirements.

All Board members, senior staff and personnel with procurement or grant-making authority must complete a written Conflict of Interest Declaration upon joining the Organisation and annually thereafter, disclosing any financial, familial or personal interest that could reasonably influence, or appear to influence, their duties.

Any new conflict arising during the year (for example, a relative applying for a vacancy, or a personal business relationship with a prospective vendor) must be disclosed in writing within five business days of the individual becoming aware of it.

A person with a declared conflict must recuse themselves from any discussion, vote, evaluation or approval connected to that conflict, and their recusal must be recorded in the minutes of the relevant meeting or decision.

Anyone with a good-faith concern about suspected corruption, bribery, fraud, conflict of interest or financial misconduct may report it through any of the following channels: the confidential email address ethics@innovativeandequal.am, monitored solely by an independent Board member who is not part of daily operations; a sealed physical suggestion box at the Yerevan head office, opened only by that same Board member; or a direct, confidential conversation with any Board member of the reporter's choosing.

Reports may be made anonymously. The Organisation does not use caller-ID-linked hotlines or any mechanism that could identify an anonymous reporter without their consent.

The independent Board member who receives a whistleblowing report logs it, acknowledges receipt to the reporter (where contact information is provided) within three business days, and convenes the Finance and Audit Committee, excluding any member implicated in the report, to oversee the investigation.

The Organisation guarantees that no person who reports a good-faith concern under this Policy will suffer dismissal, demotion, harassment, exclusion from opportunities, or any other detrimental treatment as a result, even where the concern is investigated and not substantiated.

Retaliation against a whistleblower is itself treated as a serious disciplinary offence, subject to the same investigation and sanction procedures as the underlying misconduct, and any staff member found to have retaliated is subject to dismissal.

Upon receiving a report, the Finance and Audit Committee opens a formal investigation file within five business days, appoints an investigation lead free of conflict, and, for allegations involving amounts exceeding AMD 2,000,000 or suspected criminal conduct, engages an independent external auditor or legal counsel.

The investigation gathers documentary evidence, interviews relevant witnesses, and provides the person of concern an opportunity to respond, while taking reasonable steps to protect them from assumption of guilt before findings are confirmed. A written investigation report with findings and recommendations is completed within 45 calendar days of opening the file, extendable by 30 days with Board notification for complex cases.

Where the investigation confirms a criminal offence such as embezzlement or bribery, the Organisation refers the matter to the Police of the Republic of Armenia and, for grant-related fraud, notifies the affected donor within 10 business days of confirmation.

Confirmed breaches of this Policy result in proportionate sanctions ranging from a formal written warning, through suspension without pay, to summary dismissal or termination of contract, and, in every case involving a criminal offence, referral to law enforcement and, where applicable, civil recovery action to reclaim misappropriated funds.

Contractors, suppliers and partner organisations found to have engaged in corrupt practices are permanently debarred from future business with the Organisation and reported to relevant donor due-diligence databases where such mechanisms exist.

The Finance and Audit Committee compiles an annual anti-corruption compliance report summarising the Gifts and Hospitality Register, conflict of interest declarations, procurement audit findings, whistleblowing cases and their outcomes, and sanctions applied, and presents it to the full Board no later than 31 March each year.

In accordance with RA legislation governing public organisations, the Organisation submits its audited annual financial statements and, where required, relevant compliance disclosures to the Ministry of Justice within the statutory deadline, and makes a summary of its anti-corruption governance publicly available on its website.