Anti-fraud, anti-corruption and gifts policy

1. Principle

TIPCS holds money in trust for its mission and its donors. Fraud, bribery, kickbacks, theft, forged documents, false claims, nepotism and the misuse of TIPCS assets, name or influence are forbidden and will be investigated and, where proven, sanctioned and reported to the authorities and the affected donors. The policy covers the Board, staff, experts, interns, volunteers, consultants, suppliers and partners.

2. Financial controls

• Accounts kept in line with the accounting standard for associations, with supporting documents kept for ten years.
• All receipts and payments go through the bank or post-office account of TIPCS. Cash is limited to small expenses; any transaction above 500 TND is made by bank transfer, cheque or equivalent traceable means, as the law requires. Gifts and dues are received by bank transfer only.
• Segregation of duties: the person who approves a payment does not execute or reconcile it. Two authorised signatories for payments above the limit set by the Board.
• Monthly bank reconciliation, budget-versus-actual reviews, and an inventory of assets. Annual accounts are certified by a chartered accountant and by an auditor where the legal threshold (100,000 TND of annual resources) or a donor requires it, then approved by the General Assembly and published within one month.
• Project funds are used only for the agreed purpose and recorded separately by project.

3. Bribery and facilitation payments

No one may offer, promise, give, request or accept a bribe, directly or through another person, to or from a public official, a donor, a supplier, a candidate or anyone else, to obtain or keep an advantage. Facilitation (“grease”) payments are forbidden even where customary. If a payment is demanded under threat to life, liberty or safety, pay if needed to protect the person and report it at once.

4. Gifts, hospitality and sponsorship

• Never accept or give cash or cash equivalents.
• Modest, occasional courtesies (a meal, a book, a branded item) worth less than 100 TND are acceptable if open, not linked to a decision and not repeated. Anything above must be declined or declared to the Secretary General, who records it in a gifts register.
• No gifts during a tender, grant decision, hiring or evaluation involving the giver.
• Sponsorships and donations are accepted only under the Funding and transparency page and the Sanctions and due diligence policy.

5. Staff, procurement and partners

Purchases above 1,000 TND require at least three written quotes or a documented reason why not; above the threshold set by the Board or a donor, a formal tender is run and published on the Tenders and calls page. Suppliers and partners are checked before contracting and must accept this policy in writing. Hiring is by open, merit-based procedure; relatives are not recruited into roles they would supervise or be supervised by. Expense claims need receipts and approval by another person.

6. Reporting and response

Anyone who suspects fraud or corruption must report it at once through the Whistleblowing and complaints policy, in good faith and without needing proof. TIPCS will secure evidence, suspend access if needed, investigate impartially, recover losses where possible, discipline offenders, notify donors (usually within the time their agreements set) and, where the law is likely broken, refer the case to the competent authorities. Lessons are used to strengthen controls. Retaliation against a reporter is a disciplinary offence.

7. Review

The Treasurer and the Secretary General review this policy every year and report to the Board, with a summary of cases and lessons.