Internal control and misconduct

2. PREVENTION OF MISCONDUCT

Introduction‍
Help to Help applies zero tolerance against misconduct. Our approach is to always prevent,never accept, always inform and always act even in situations where misconduct might lead todelays, hindrance or total obstruction of operations.

Misconduct includes corruption, illegal actions, discrimination, sexual harassment, conflicts ofinterest and other types of unethical behaviour. Help to Help use the definition of corruptionused by the Swedish International Development Cooperation Agency, Sida. Sida defines corruption as an; abuse of trust, power or position for improper gain. Corruption includes, amongother things, the offering and receiving of bribes – including the bribery of foreign officials – extortion,conflicts of interest and nepotism

Help to Help uses the definition of sexual harassment used by the United Nations: Sexual harassment is any unwelcome sexual advance, request for sexual favour, verbal or physical conduct orgesture of a sexual nature, or any other behaviour of a sexual nature that might reasonably be expected or be perceived to cause offence or humiliation to another, when such conduct interferes with work, is made a condition of employment or creates an intimidating, hostile or offensive work environment.This policy applies to all Help to Help’s employees, volunteers, and board members.Volunteers refer to all temporary personnel such as volunteers, interns, trainers, and mentors.The policy should permeate all Help to Help’s work in Sweden and East Africa and elsewhere we might operate in the future. It should be applied both internally and in collaboration with our partners.

Always Prevent
There are some common situations that may pose a risk for misconduct:

Opportunity: Prevention means minimising opportunity
Organisational culture: messages from management, lack of transparency
Tolerance in society

Help to Help’s operational work is conducted in countries where corruption is prevalent andthe organisation must acknowledge corruption risks when establishing and applying internal rules and routines in Sweden and East Africa. Help to Help and Help to Help’s partners shall therefore:

Raise awareness about corruption internally
Assess corruption risks in all projects, programs and activities
Identified risks shouldbe appropriately addressed and followed up
Strengthen good governance and internal control both internally and in partnerorganisations
Develop a good organisational culture in which employees act responsible and fair.Help to Help should be a good employer and employees should be treated fairly andcompensated adequately.

Responsibility

All employees at Help to Help and all partner organisations, regardless of position ortask, are covered by this policy.
Help to Help shall ensure that partners such as donors and collaborators are aware ofand apply this policy on misconduct.
The Managing Director shall ensure that this policy and related guidelines onsuspected corruption is known and applied by all employees and volunteers.
All employees are required to work actively to prevent misconduct by identifying,recognizing, handling and acknowledging risks for misconduct throughout the organisation, as well as reporting irregularities and suspected cases of misconduct.

Commitment

This policy should be included in all Help to Help’s agreements with partners withinprojects or programs, both Swedish and international.
This policy shall be applied in all procurement procedures.
Employees, volunteers, and board members may not participate in decisions norprepare decisions in cases where his/her impartiality can be questioned. Impartialitycan e.g. refer to when someone in the organisation has a private relationship with acandidate for a new position or is related to a potential supplier. Employees andvolunteers are required to inform their supervisor of any circumstances where theirimpartiality may be questioned. Board members have an obligation to announcethemselves biased in relevant situations.
Employees, volunteers, and board members may not act on behalf of the organisation,financially or in any other matter, beyond their authority.
Employees, volunteers, and board members may not accept gifts from potentialbeneficiaries or their families. This includes both the Scholarship Programme and Helpto Help Academy. Employees, volunteers, and board members may accept gifts fromenrolled students and current participants within Help to Help Academy and theirfamilies and partners if it would be perceived as impolite not to accept the gift.However, the gifts need to be reasonable, of insignificant value, have a legitimatepurpose and do not create a conflict of interest or the perception thereof. Gifts shouldto the extent possible be used by the organisation as a whole and not the individualwho received it e.g. sharing a box of chocolate with everyone and not bringing it home.However, gifts such as a photo of an individual, can be carried home and handled bythat individual. Overall, employees are encouraged to assess the nature of the gift and determine how it can be used by the whole organisation.

Always Act

When suspected misconduct arises, Help to Help must immediately take action to minimiseany damage and ensure a prompt investigation. The responsibility to investigate suspectedcases of misconduct, report to the two boards and, when applicable, the donors, lies on theManaging Director. However, if the suspicions concern the Managing Director, the Chairperson of the Board of Help to Help Sweden will be responsible.

In case of suspected corruption or misconduct, the following steps should be considered:

Discussion with the person reporting the suspicions.
Discussion with the person affected (in case of misconduct).
Discussion with the supervisor of the person being accused.
Discussion with the person being accused to inform about internal rules and values aswell as the legal framework. Inform about the action plan which may include warnings,termination, and reporting to the police.
Inform other employees, partners and stakeholders (e.g. beneficiaries) about thesituation and action plan.6. Follow up the action plan and investigate if internal routines need to be strengthened.
All steps shall be properly documented.

The Managing Director or Chairperson might choose to report the case to the police duringany steps in the process. If the suspected crime is reported to the police, the police will takeover the investigation. The Managing Director or Chairperson might also choose to engage anauditor in case of financial misconduct.

Always Inform

An open and transparent approach is important when working against corruption. A personwho suspects irregularities is not required to provide proof or have full knowledge of the casebefore reporting the case. A person who reports suspected irregularities will not be subjectedto harassment or reprisals. Donors, auditors and other stakeholders should also be informed early on by the Managing Director of Help to Help.

Whistleblowing Procedures

Students, volunteers, mentors, trainers, employees, partners, or other individuals areencouraged to report suspected cases of misconduct to Help to Help. All complaints should bereported to the Managing Director of Help to Help Sweden or the Chairperson of Help to HelpSweden via complaints@helptohelp.se.
It is important for anyone who considers making allegations to ensure that they are sincereand substantiated. No allegations should be made maliciously or with the knowledge that theyare false.

3. INTERNAL CONTROL

Internal Control Help to Help Sweden

Roles and Responsibilities

The Board
The Board of Help to Help Sweden approves the global organisation’s Annual Budget and has aguiding document (attachment Board Routines) specifying the procedure for its work. TheBoard shall evaluate outturn of income and expenditure in relation to the budget at least fourtimes per year. The Board is responsible for ensuring that Help to Help Sweden is abiding with Swedish laws and the organisation's own policies.

The Board of Help to Help Sweden shall on an annual basis evaluate whether the organisationis using its resources in a sustainable way in accordance with the objectives and if neededdecide upon necessary changes to the operations. In relation to the evaluation, certain focusshall be on the organisation’s efficiency in terms of administration and fundraising activities.The evaluation shall be documented in writing.

The organisation must not have any inappropriate expenditure. At least 75% of the total fundsraised must be used to fulfil the objectives and the operational activities.

Managing Director
The Managing Director of Help to Help, is responsible for all financial administration, for fundraising, procurement, invoicing, attestation, preparation of annual budget and financial and annual reports.

The Accountant
Help to Help Sweden has contracted Hjorth & Partners for bookkeeping, payments of supplierinvoices, salaries and taxes and preparing financial statements.

The Auditor
Help to Help Sweden is audited on an annual basis by Felicia Krusell, authorised accountant atRSM Stockholm AB. Help to Help has at least one authorised auditor or approved auditing firmin Sweden, regulated by the Swedish Inspectorate of Auditors.

Transaction of Funds to Third Parties such as Help to Help Tanzania

The purpose of this chapter is to describe in detail how money that has been raised in Swedenby Help to Help Sweden is being transferred to Help to Help Tanzania It further describes howthe money received by Help to Help Tanzania is handled and monitored.

There is only one (1) recipient in Tanzania of donations from Help to Help Sweden which isHelp to Help Tanzania.

Four times per year, Help to Help Sweden transfers funds to Help to Help Tanzania accordingto the Quarterly Budget and Annual Strategic and Operational plan. Decisions about transactions are taken by the board of Help to Help Sweden.
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The transactions are made from Help to Help SWE’s bank account in SEB to Help to HelpTanzania’s USD bank account in Absa Bank Tanzania. Help to Help Tanzania also has a bank account in Tanzanian Shillings (TZS) with the same bank.

Funds are transferred from the USD account to the TZS account in order to be able to make transactions and payments in the local currency.

Help to Help Tanzania reports how the funds have been used through a Quarterly Narrative and Financial Report to the Board of Directors of Help to Help Tanzania at every Board Meeting.

Mandate to Approve Expenditure

The Board of Help to Help Sweden approves expenditures in advance as part of the approval of the annual budget. For individual transactions within budget, the Chairperson of the Board oranother Board member approves transactions of expenditure above 50 000 SEK, except for salaries and social security contributions, which are approved by the Managing Director. For other expenses, the Managing Director approves transactions amounting to a maximum of 50 000 SEK.

For individual transactions that are above budget, the Chairperson of the Board or anotherBoard member approves transactions of expenditure above 20 000 SEK. The Managing Director approves transactions amounting to a maximum of 20 000 SEK.

For individual transactions within or above budget that are not salaries and social security contributions and amount to more than 200 000 SEK, two board members approve the transaction jointly.

Signatories
The Managing Director and the Chairperson of the Board are authorised signatories for Helpto Help. They have the mandate to sign for the organisation separately.

Invoicing
The Managing Director is responsible for all legal agreements with partners as well as invoices. Invoices are sent to partners and donors via email.

Cash Management
Help to Help Sweden does not handle cash neither for donations nor expenditures. Donations are accepted via credit card transactions, digital bank-ID transfer, mobile transfer or swift transfer to Help to Help’s bank account. Expenditures are paid with the organisation’s credit card or by employees who get reimbursed afterwards.

Risk Management
The Board of Help to Help Sweden shall on an annual basis make a risk analysis and based on that make a risk management plan. The risk management plan shall include the following risk categories:‍

External risks e.g., political, societal risks, conflicts, terror, etc.
Operational risks e.g., employees, legal and security related risks
Reputation e.g., unethical behaviour, inappropriate partners, etc.
IT risks, e.g., data leakage, IT damage control, etc.
Legal risks e.g., accounting, labour laws, taxes
Financial risks e.g., liquidity, currency risk, etc.
Accounting and reporting e.g., internal reports for monitoring and evaluation, whistleblowing to the managing director and the board.

The Board shall on an annual basis evaluate how the organisation is living up to and following the risk management plan.

Internal Control Help to Help Tanzania

Roles and Responsibilities

The roles and responsibilities for the above functions are described in the Constitution of the Organization.
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The Chairperson, Treasurer and Executive Secretary of the Organization
The Chairperson, the Treasurer and the Executive Secretary of the Organization are signatories of the organization and have authorizing power for payments.

The Regional Director (RD)
The Regional Director is responsible for financial administration, procurement, invoicing, preparation of annual budget and financial and annual reports.

The Accountant
The Accountant is responsible for bookkeeping, initiating all office expenditures and preparing financial reports.

The Auditor
Help to Help Tanzania is audited on an annual basis by Uhuru Auditors, Dar es Salaam, Tanzania.

Application for Funding and Budget
Help to Help Tanzania prepares an Annual Budget that is approved by the Annual General Meeting of Help to Help Tanzania and the Board of Help to Help Sweden. Furthermore, Help to Help Tanzania apply for funding from Help to Help Sweden every quarter. The application must include information about the activities in the upcoming quarter and the Quarterly Budget. The application is approved by the Board of Help to Help Sweden. The Board of Help to Help Sweden approves expenditures in advance as part of the approval of the Annual and Quarterly Budget.

Signatories
‍The Chairperson, the Treasurer and the Executive Secretary of the Organization are authorised signatories for Help to Help. They have the mandate to sign for the organisation separately. The Regional Director is the lawful attorney and agent in fact for the organisation for the following:
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To sign and make necessary amendments on behalf of the organisation for all documents related to the following organisations:Workers Compensation Fund, SSF Pensions Fund, Tanzania Revenue Authority, Higher Education Students Loan Board, Ministry of Health Community Development Gender Elderly Children, Other government institutions
Agreements between Help to Help Sweden and Help to Help Tanzania
Applications for support to donors, such as Help to Help Sweden
Contracts regarding suppliers or service providers up to an amount of 2,500,000 Tanzanian shillings.
Contracts regarding suppliers or service providers above 2,500,000 Tanzanian shillings after approval via email from the Treasurer or Chair of the organisation
Contracts for hiring volunteers and interns.
Employment contract after approval by the Treasurer or Chair of the organisation

‍Mandate to Approve Expenditures
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Individual Transactions Within the Budget
‍For individual transactions within the budget, the RD approves amounts up to 10,000,000 TZS.

For individual transactions within the budget, the Treasurer approves amounts between 10,000,000 TZS and 25,000,000 TZS.

For individual transactions within the budget, above 25,000,000 two office bearers approve jointly.

Individual Transactions in Excess of The Budget
‍For transactions in excess of the budget, the RD has the mandate to approve amounts up to 500,000 TZS at a given time (one individual transaction) and in total up to 1,000,000 TZS in one quarter. Excess of the budget means more than the approved budget per budget item within the quarterly budget.

For transactions in excess of the budget, the Treasurer has the mandate to approve amounts up to 5,000,000 TZS at a given time (one individual transaction) and in total up to 10,000,000 TZS in one quarter.

All amounts above that need to be approved by two office bearers jointly.

Suppliers
For all purchases above 2,500,000 TZS the purchase process must be conducted on quotation basis. Purchases below 2,500,000 TZS do not require a procurement process and the Regional Director has the mandate to approve the purchases in line with the mandate described above. The Treasurer has the mandate to make procurement decisions in line with the budget up to, but not including 25,000,000 SEK. All amounts above that need to be approved by two office bearers jointly. Contracted recurring suppliers are approved by the Treasurer.

Cash Management
Help to Help Tanzania’s transactions are in >95% of the cases paid via Absa Bank Tanzania online bank such as salaries, taxes, authority fees, supplier invoices, school fees for students, etc.

The school fees for beneficiaries within Help to Help’s Scholarship Program are paid directly from Help to Help Tanzania’s account in TZS to the respective universities. The school fees are paid according to the invoices provided by the universities.

Minor expenses such as waste collection, inter-regional transport and emergency operational expenditure are paid in cash by employees. Cash payments are approved beforehand by the appropriate supervisor. Employees report back on all expenses within two weeks (Program and Project Managers) after the expenditure. The Regional Director reports monthly.

Only the Office Bearers have the power and access to authorise payments with Absa Bank Tanzania.Almost all expenditure in Tanzania can be traced directly in transcripts from the bank.

Books are kept in the online accounting software Quickbooks. The system is considered of high international standards.

More detailed information about how payments are handled can be found in the Policy for Financial Procedure.

Risk Management
The Board of Directors shall on an annual basis make a risk analysis and based on that make a risk management plan. The risk management plan shall include the following risk categories:
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External risks e.g., political, societal risks, conflicts, terror, etc.
Operational risks e.g., employees, legal and security related risks
Reputation e.g., unethical behaviour, inappropriate partners, etc.
IT risks, e.g., data leakage, IT damage control, etc.
Reputation e.g., unethical behaviour, inappropriate partners, etc.
Legal risks e.g., accounting, labour laws, taxes
Financial risks e.g., liquidity, currency risk, etc.
Accounting and reporting e.g., internal reports for monitoring and evaluation, whistleblowing to the managing director and the board.

The Board shall on an annual basis evaluate how the organisation is living up to and following the risk management plan.

Related Documents
Information about Help to Help Tanzania’s financial procedures, including transaction of funds, cash management and procurement can be found in the Accounting Manual and the Policy on Financial Procedures.

Help to Help Tanzania’s Accounting Manual can be found here and the Policy on Financial Procedures here.

‍Help to Help’s Code of Conduct can be found here.Help to Help’s Student Agreement can be found here.

‍Help to Help’s Fundraising Policy can be found here.

‍Board Routines for Help to Help Sweden here and Help to Help Tanzania here.
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internal control and misconduct

Privacy policy Allmänt om Help to Help och 90-konto (sv) Cookie policy FAQ

1. INTRODUCTION

2. PREVENTION OF MISCONDUCT

Responsibility

Commitment

Always Act

Always Inform

Whistleblowing Procedures

3. INTERNAL CONTROL

Internal Control Help to Help Sweden

Roles and Responsibilities

Transaction of Funds to Third Parties such as Help to Help Tanzania

Mandate to Approve Expenditure

Internal Control Help to Help Tanzania

Roles and Responsibilities

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Privacy policy Allmänt om Help to Help och 90-konto (sv) Cookie policy FAQ

Privacy policy Allmänt om Help to Help och 90-konto (sv) Cookie policy FAQ