Anti-Fraud, Anti-Corruption & Conflict-of-Interest Policy
One Citizen Humanity (OCH) – Official English Version
1 · Purpose & Scope
In line with Article 6 “Transparency, Finance & Non-Profit Status” of the OCH Constitution, this policy sets out a zero-tolerance framework against fraud, corruption and undisclosed conflicts of interest (COI). It applies to every person and entity acting for or on behalf of OCH — staff, Board members, volunteers, consultants, suppliers, grantees and partners.
2 · Definitions
| Term | Meaning |
|---|---|
| Fraud | Any intentional act of deception designed to secure an unfair or unlawful gain. |
| Corruption | Abuse of entrusted power for private benefit (e.g. bribery, kickbacks). |
| Conflict of Interest (COI) | A situation where personal interests could improperly influence, or appear to influence, professional duties. |
3 · Guiding Principles
- Legality & Integrity – comply with all applicable laws.
- Accountability & Transparency – complete, timely and accurate records.
- Segregation of Duties / Four-Eyes Principle – no single person controls an entire financial process.
- Proportionality – controls match the risk level and size of transaction.
4 · Roles & Responsibilities
- Board of Directors: sets the tone at the top and approves this policy.
- Chief Financial Officer (CFO): maintains internal controls, monitors compliance.
- Ethics Committee: receives reports, oversees investigations, recommends sanctions.
- All Personnel: must prevent, detect and report irregularities immediately.
5 · Preventive Controls
| Control | Threshold / Rule |
|---|---|
| Competitive procurement | Required for all contracts > €2 000 (at least three quotes). |
| Gifts & hospitality | Acceptable up to €50 per external party per calendar year; anything above must be declared. |
| COI disclosure | Annual signed form for staff & Board; ad-hoc update within 7 days of any new conflict. |
| Dual sign-off | Payments ≥ €1 000 require two authorised signatories. |
| Finance system access | Role-based permissions; monthly access review. |
6 · Reporting Channels & Whistleblower Protection
- Secure Report Portal : https://onecitizenhumanity.org/report/
- Email: info@onecitizenhumanity.org
- Postal mail: Ethics Committee, One Citizen Humanity, Kungsholmsgatan 10, Unit #194, 112 27 Stockholm
Good-faith reporters are protected from retaliation; breaches lead to disciplinary action.
7 · Investigation & Sanctions
- The Ethics Committee appoints an independent investigator within five working days.
- Findings are reported to the Board; substantiated cases may result in dismissal, contract termination, restitution, or legal action.
- OCH cooperates fully with law-enforcement and funding agencies.
8 · Record Keeping & Data Protection
Investigation files are retained for at least seven (7) years, stored encrypted, and accessed only by authorised personnel, in line with GDPR and applicable data-protection laws.
9 · Training & Awareness
- Mandatory annual briefing for finance, logistics, procurement and leadership teams.
- Introductory training for all new personnel within 30 days of onboarding.
- Updates disseminated whenever laws or donor requirements change.
10 · Monitoring & Review
- Internal control audits at least once per year.
- Policy effectiveness reviewed every two years or immediately after a major incident; revisions approved by the Board.
Last updated: Feb 2026
