The development and humanitarian activities of Danish civil society organizations often take place in countries where corruption is a widespread phenomenon—often to an extent that significantly hampers the country's development and the legal standing of its population. Particularly in fragile contexts and during crises, there is an increased risk of corruption, as evidenced during the COVID-19 pandemic.
Therefore, CISU aims to have a constructive focus on anti-corruption and to strengthen the capacity of Danish organizations and their partners to prevent and address corruption through capacity building, advisory services, and support.
All CISU grant holders are obliged to immediately (within a maximum of 14 days) report to CISU if they discover (or have reasonable suspicion of) fraud, corruption, misuse, or any other irregularities related to the grant.
CISU defines corruption, in line with many others, as:
“Abuse of entrusted power and resources for private gain.”
It is incredibly difficult to measure corruption. Transparency International publishes the Corruption Perception Index each year, which measures the perception of a country's level of corruption. However, the challenge with this is that it is based on subjective understandings and generalizations from experts and businesspeople in other countries regarding the public sector of the country in question.
Acknowledging that there is no universally accepted definition of corrupt behavior, we assert that corrupt and dishonest practices include the following actions:
- Fraud: Fraud and fraudulent behavior refer to deliberate acts committed by management or other individuals for personal gain. This includes extortion, conspiracy, deceit, nepotism, theft, embezzlement, forgery, and inflated pricing.
- Corruption: Corrupt behavior and practices occur when payment beyond normal rates is offered in exchange for special services or expedited processing.
- Misuse of funds: This is understood as the use of money and assets (such as service vehicles, phones, etc.) for purposes other than the project, as well as inadequate or inappropriate maintenance of assets.
- Serious irregularities: This refers to inadequate bookkeeping, delayed or missing financial reporting to partners and donors, and other forms of management misconduct.
- Acceptance of or offering gifts or services that are more than symbolic, i.e., other than pens, calendars, etc. No one should request or receive gifts that could influence their work or decisions, even if the gift is given to family members.
- Secrecy, concealment, or omission: Keeping information secret or hiding potential conflicts of interest in dealings with partners, service providers, suppliers, and business partners. This also includes attempts to conceal close family relationships, ownership stakes, co-ownership, and other important connections.
Transparency International has developed a Corruptionary, where they describe the many different types of corruption
Anti-corruption: What should your organisation do?
Preventing corruption and fraud starts at the beginning of a partnership or the development of a specific project. It is important to discuss how corruption, misuse, and fraud can be prevented. Taking time within the partnership to clarify expectations and understand each other’s organizations and backgrounds is essential, as it allows for a better understanding of the context from which one reacts and speaks.
Therefore, you need to have an anti-corruption policy and procedures for your organization, partners, and target groups. See our tips for a suggested ouline of such a policy further below.
In a development and humanitarian context, there are several risk areas that are important to keep in mind. These may include:
- “Ghost lists” (ghost volunteers who receive per diems, ghost events, ghost staff, etc.)
- “Double-dipping” (obtaining funds from more than one donor for the same expenses of a project)
- “Sextortion” (extortion that involves sexual acts or images as currency)
- Governance set-up allowing nepotism
- Urgency to spend (at the end of the funding cycle, some unnecessary expenses generate waste)
- Lack of control over financial systems of secondary partners for implementation; lack of comprehensive reporting
- Lack of due diligence practice
- Security payments at check points
Additionally, one should be aware of weak procurement and tendering systems, cash transactions, currency transactions, money laundering via obscure donors, gifts with quid pro quo, kickbacks, intermediary services, and customs processing.
