Complaint Response Mechanism (CRM) Anti Fraud Policy & Complaint Response Mechanism (CRM) November 2015

Concern Worldwide Major Donors included USAID/OFDA, ECHO, DFID and EU.

Concern Worldwide Working through local and international NGOs partners/sub-grantees Implementing USAID RAPID Fund and CBDRM Programs Apart from development projects, Concern is responding to Complex Emergencies (TDPs/Return), Flood, Drought and Earthquake Under RAPID Fund (Phase I and II) worked with more that 90 NGOs , implemented about 200 short term emergency project throughout Pakistan.

Commitment to Accountability Commitment to being accountable to our stakeholders Concern’s 2005 Governance Framework and Strategic Plan 2011-2015 In 2007, Concern joined the HAP-international self-regulatory body, committed to meeting the highest standards of accountability. Accepting responsibility for doing what we say we will do; being open and transparent about what we do, why and how we do it; and responding promptly to complaints or concerns about our work.

Policy Framework Programme Participants Protection Policy Anti Fraud and Whistle blowing Policy Investigation Guidelines Anti Fraud Strategy Complaint Response Mechanism

Policy Framework Programme Participant Protection Policy Protection of the rights of the program participants Focus on Code of Conduct and Behavior/ harassment issues Part of the agreement/contract (employee/partners/supplier)

Policy Framework Anti Fraud and Whistle blowing Policy Access to Anti Fraud hotline numbers Encourage Whistle Blowing Part of the agreement/contract (employee/partners/supplier)

Policy Framework Complaint Response Mechanism (CRM) CRM is ensured in all programs (Phone/hotlines, Complaint Box, email, In person) Stake Holders have access to CRM They know about their entitlement/rights (orientation, banners) Coordination with stake holder (UN cluster, PDMA, District authorities) (know about what we are delivering) Complaints are received and processed by independent team members, not involved in implementation of projects

Accountability/ Transparency Community Involvement in project planning, design and implementation Competitive process of sub-grants/partners selection Project information (all details) shared with all stakeholders (4Wmatrix) Regular Monitoring and support to partners/sub-grantee Internal and External Audits External Evaluation of Program

A study which was commissioned by UN- IASC Humanitarian Financing Task Team A positive example of good practice was found in Pakistan where OFDA and Concern Worldwide have jointly set up a pooled emergency fund for NGOs which works very efficiently. Reverting to the good practice example from the Pakistan RAPID Fund once more, the fund has invested considerable efforts in making the entire application process as transparent as possible for applicants, using graphics and flow charts and FAQs. It makes the fund appear customer and service oriented, actively encouraging applicants to prepare as well in advance as possible http://reliefweb.int/report/world/partner-capacity-assessments-humanitarian-ngos-fit-purpose

Challenges & Mitigation Capacity of local partners to implement CRM policies and procedures at Partner level trained staff to carry out investigations trained staff to implement a robust CRM   Proper orientation of partner staff, on job capacity building/monitoring and effective communication of policies and procedures for better awareness. Invalid complaints/Budget constraints  Fact finding before formation of investigation committee

Conclusion We aim to design our procedures/systems to minimize misuse of funds/resources and instances of fraud We make changes to our controls / systems based on the weaknesses highlighted through CRM/routine audits/monitoring visits/feedback from stakeholders Strict disciplinary actions are taken in proven cases of fraud/harassment – dismissal of staff; termination of partnership with partners