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

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

3. 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.

4. Commitment to Accountability
Commitment to being accountable to our stakeholders
Concern’s 2005 Governance Framework and
Strategic Plan
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.

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

6. 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)

7. 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)

8. Policy Framework Complaint Response Mechanism (CRM)
CRM is ensured in all programs (Phone/hotlines, Complaint Box, , 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

9. 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

10. 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

11. 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

12. 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