POLICY PROHIBITING AND COMBATTING FRAUD AND CORRUPTIONFirst Edition

November 2022

INTERNATIONAL TROPICAL TIMBER ORGANIZATION

Adopted by the International Tropical Timber Council at its 58th Session

POLICY PROHIBITING AND COMBATTING FRAUD AND CORRUPTION
Section 1 Preliminary Provisions
General Introduction
This statement of ITTO’s Policy Prohibiting and Combatting Fraud and Corruption affirms
ITTO’s long-standing zero tolerance for all forms of fraud, corruption, and related misconduct,1and outlines the steps to be taken in response to good faith reports of possible violations of thepolicy.
Applicability
Executive Director, Staff and Non-Staff Personnel
1.1 The Executive Director, all staff members, non-staff personnel, and personnel of thirdparties, including vendors and executing agencies, entering into agreement with ITTO arerequired to comply with this Policy.
(a)The “Executive Director” is the chief administrative officer of the Organization
appointed by the International Tropical Timber Council in accordance with Article 12 of theInternational Tropical Timber Agreement, 2006, and is responsible to the Council for theadministration and operation of the Agreement.
(b)
A “staff member” is any person holding a Letter of Appointment to ITTO signed
under the authority of the ITTO Executive Director.
(c)“Non-staff personnel" includes any person who is working with ITTO as a volunteer,
under stand-by Personnel arrangements in emergencies, under a reimbursable loan, internship,
through an employment agency, or any similar arrangement; it does not include individual
consultants or contractors.

Vendors (including Consultants) and Executing Agencies
1.2 ITTO individual consultants and contractors are also expected to maintain the highest

standard of conduct in connection with their engagement with ITTO. A commitment to thehighest ethical standards is a major consideration in the selection of individual consultants andcontractors at ITTO.
1.3 ITTO vendors (including individual and institutional consultants) and Executing Agencies arealso expected to adopt and enforce robust policies combatting fraud and corruption. Those
policies are expected to be no less stringent than this Policy.

Definitions
1.4 In this Policy, “fraud“ means the actual or attempted use of deceit, falsehood, or dishonestmeans (including willful omission) to secure direct or indirect financial or material gain, personaladvantage or other benefit, and includes fraudulent, corrupt, collusive , coercive andobstructionist conduct (as defined below). It includes attempted fraud (even if unsuccessful).
(a)“Fraudulent conduct” is any act or omission, including a misrepresentation, thatknowingly or recklessly misleads, or attempts to mislead, a party in order to obtain a financial orother benefit or to avoid an obligation;(b)“Corrupt conduct” is the offering, giving, receiving, or soliciting (in each case, directly
or indirectly) anything of value in order to influence improperly the actions of another party;

1Hereafter this policy may use to the term “fraud” to mean fraud, corruption, and related misconduct, as defined in Section 1.4 ofthis policy.

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(c)
“Collusive conduct” is the proposing or entering into an arrangement between two or
more parties designed to achieve an improper purpose, including influencing improperly theactions of another party;(d)“Coercive conduct” is the impairing or harming, or threatening to impair or harm,
directly or indirectly, any party or the property of the party in order to influence the actions of thatparty or another; and(e)“Obstructive conduct” is (i) any act which deliberately and in an effort to compromise
an investigation, destroys, falsifies, alters or conceals information or documents that may berelevant to a fraud and corruption investigation, or material that could become evidence as aresult of such investigation; or (ii) the making of false statements to investigators during such aninvestigation which obstructs the course of justice.

Section 2 Policy against Fraud and Corruption
2.1 The Executive Director, ITTO staff members, non-staff personnel, and personnel of thirdparties entering into agreement with ITTO are not to engage in fraud.
2.l (a) Fraud against ITTO will constitute misconduct and will be grounds for serious
disciplinary and/or administrative actions and/or dismissal. It may lead to actions to recover any
losses sustained by ITTO as a result of such fraud (including referral to law enforcement
authorities).
2.1 (b) Fraud against others will also constitute misconduct, being conduct unbecoming of
an international civil servant, and will also be grounds for serious disciplinary and/oradministrative actions and/or dismissal.
2.2 ITTO vendors (including individual consultants and contractors, and institutional consultants)
and executing agencies are not to engage in fraud.
2.2(a) Fraud against ITTO will constitute grounds for probation, suspension, or terminationof the relationship with ITTO. It may also lead to actions to recover any losses sustained by
ITTO as a result of such fraud (including referral to law enforcement authorities). ITTO will
maintain a list of vendors (including individual consultants and contractors, and institutionalconsultants) and executing agencies sanctioned for fraud and will make this list available toCouncil.
2.2(b) Fraud against others will disqualify such vendor/s (including individual andinstitutional consultants and contractors) or executing agencies from further engagements withITTO.
2.3 ITTO will address all allegations of fraud involving or impacting on ITTO;
2.4 Managers who fail to take appropriate action in this connection or who directly or indirectly
tolerate or condone improper activity under this policy may be held accountable for violations of
this policy, as well as under ITTO staff regulations and rules and the Standards of Conduct for
the International Civil Service.
Section 3 Reporting Procedures and Subsequent Actions
Reporting
3.1 ITTO staff members and non-staff personnel, as defined in 1.1.c, are required to report allreasonable suspicions of fraud involving or impacting on ITTO to Senior Management. WhereSenior Management is either implicated in the complaint or the complainant has reasonable
belief that Senior Management has an interest in the outcome of the claim, staff members andnon-staff personnel may report suspicions of fraud to the Executive Director and/or one or moremembers of the ITTC. The Executive Director shall report all claims of fraud to the ITTC in atimely manner.

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3.2 ITTO vendors (including individual consultants and contractors, and institutional consultants)
and executing agencies are also required to report in good faith suspicion of fraud involving orimpacting on ITTO as soon as possible.
3.3 Reports must be made in good faith. Making a false or malicious allegation is not permitted
or protected, and may result in disciplinary action in accordance with applicable rules andprocedures.
3.4 Reports can be made anonymously, though anonymous reports that lack specific details
will be reviewed but may not be pursued further if the report does not include sufficient
supporting material.
Preliminary Review of Claims
3.5 The officials responsible for receiving claims of suspected fraud and corruption (“ReviewingOfficial”) will review the available information and make a determination as to:a. Whether the claim(s) was submitted in good faith; andb. The suspected conduct, if true, would constitute an act of misconduct as defined insection 1.4 of this policy.
3.6 If the review official determines the claim was either not submitted in good faith or would notconstitute an act of misconduct under section 1.4 of this policy, he/she shall close the case,notify the complaint of the outcome, and report the same to the Executive Director, or in theevent the Executive Director is the Reviewing Official, to the ITTC, as appropriate.
3.7 If the reviewing official determines the claim was made in good faith and would constitutemisconduct under section 1.4, she or he shall refer the claim for investigation as provided insection 3.8 of this policy. The reviewing official shall also notify the claimant and ITTC of same.
Investigations
3.8 Claims deemed to require full investigations shall be referred, in consultation with the ITTC,
in a neutral and factual manner to an appropriately skilled external investigative entity, such as
the investigative function of a UN entity, a certified forensic audit consultant, or a private legal
firm. In the event the conduct concerns Senior Management or the Executive Director, the ITTC
shall independently engage the investigative entity. ITTO shall additionally ensure theavailability of adequate financial resources to cover the costs of such investigations.
3.9 The external investigative entity shall be granted full, unimpeded access to all individuals or
information it deems pertinent to an investigation. All staff members, non-staff personnel, andother third parties covered under this policy are required to cooperate fully with investigations.
ITTO vendors and executing agencies are required to ensure that their personnel and agents(including their attorneys, accountants, and other advisers) also cooperate fully with suchinvestigations.
3.9 The selected external investigative entity will investigate the claim(s) to determine whether
any misconduct and/or harm occurred and submit a detailed report on the outcome of its
investigation to the Executive Director or the ITTC Chair, as appropriate, for disciplinary actionin accordance with the ITTO Staff Regulations and Rules. ITTO may additionally makereasonable efforts to recover financial losses. ITTO shall refer to Member State law
enforcement authorities any suspected activity requiring criminal investigation, in accordancewith relevant Council decisions in the case of criminal conduct by ITTO staff members orindividual consultants.
3.10 In the event that the claim concerns the Executive Director, the ITTC Chairperson shall, inconsultation with the full Council, determine the most appropriate action to be taken, if any.
Appeals
3.11 Where a complainant or alleged offender has grounds to believe that the procedure
followed or administrative decision taken with respect to a claim of misconduct under this policy-3-was improper or erroneous, he or she may appeal the action pursuant to chapter 8 of the ITTO
Staff Regulations and Rules,Section 4 Reporting; Disclosure; Confidentiality; Public Statements
4.1 The Executive Director shall report to the ITTC via the Committee on Finance andAdministration, the following information on an annual basis, giving due regard to all applicable
personal data and privacy protections: the number and type of all claims of fraud and corruption
filed under this policy; a description of all fraud cases investigated or under open investigation
by ITTO; the disposition of all cases investigated; a description of any disciplinary actions
implemented as a result of investigative finding; and any financial or other losses incurred by theorganization as a result of such instances.
4.2 Full investigation reports shall be made available to those with affirmative duties under thispolicy and to ITTO Member States pursuant to performing bona fide oversight responsibilities.
All those given access to investigation reports have a duty to treat all information contained
therein with utmost discretion and in conformity with relevant privacy decision of the ITTC.
4.3 ITTO may decide to make public disclosure of the fact that it has received reports indicating
it may have been the victim of fraud and of the status of any response to such reports.
4.4 All disclosures relating to reports that ITTO may have been the victim of fraud and thestatus of ITTO’s response (including reports to the ITTC/Committee on Finance andAdministration) will be made in accordance with the following principles:(a) In order to ensure the probity of any investigation of possible fraud, to maximize theprospect of recovery of funds, and to respect the due process rights of all involved, information
relating to reports of fraud and investigation and handling of such reports is to be treatedconfidentially and with utmost discretion even within ITTO.
(b) All disclosure of information will be subject to the relevant decisions of the ITTC.

Section 5 Protection from Retaliation (“Whistleblower Protections”)

5.1 Any individual who makes a report in good faith under this policy or cooperates in goodfaith with any duly authorized investigation has the right to be protected against retaliation andto all due process, as provided in the ITTO Whistleblower Policy (see Annex 1 of the Staff
Regulations and Rules). ITTO expects its institutional consultants and contractors, suppliersand vendors, and executing agencies, to have similar appropriate anti-retaliation/whistleblower
policies in place. The ITTO Director of Operations and the ITTO Finance/Administrative Officer
will bear primary responsibility to ensure the possibility of vendors meeting these expectations.
Section 6 Policy Maintenance
6. 1 The Executive Director is responsible for the administration, revision, interpretation andapplication of this policy. The policy will be reviewed periodically and revised as needed.

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