ANTI-CORRUPTION AND  ANTI-BRIBERY POLICY

Introduction

TAHMO will not tolerate any form of corruption or bribery, it’s the duty of every TAHMO employee to reinforce this policy as well as respect the organization’s ethics and code of conduct.

TAHMO will conduct and implement project activities with high professionalism, honesty, and integrity and ensure all matters are straightforward to avoid violation of the anti-corruption and anti-bribery policy that applies to all employees including the CEO, Directors, managers, contractors, and subcontractors.

The purpose of this policy is to foster a culture of integrity, trust, transparency, and ethical conduct within TAHMO.

Definition

Corruption is a form of dishonesty or a criminal offense undertaken by a person or organization entrusted in a position of authority to acquire illicit benefits or abuse power for one’s gain.

Bribery is the offering, giving, receiving, or soliciting of any item of value to influence the action of an official or other person to persuade them to do something for you.

TAHMO is committed to complying with all applicable anti-corruption laws; both domestic and international laws and regulations.

No TAHMO employee shall engage in any behavior that may indicate any form of corruption or bribery like offering or accepting kickbacks or any form of improper advantage. Violation of the anti-corruption policy may result in penalties, and civil crimes with imprisonment according to respective laws and regulations of the TAHMO countries of operation.

To avoid any behavior or indication of corruption including bribery, TAHMO employees will do the following:

• Follow the Code of conduct, policy, law, and regulations of the organization as well as National, regional, and international laws.
• Not to authorize any indication of corrupt behavior, action, and activity.
• Not to get involved with any fraudulent activities and dishonest offers.
• Not to ask, pay or receive bribery from any person, office, or company for personal gains or that for TAHMO.

Third-party due diligence

TAHMO will conduct due diligence on all its third parties to avoid the risk of working with corrupt third parties, agents, distributors, and partners.

TAHMO will perform a risk assessment of all third parties before engaging them in any activity or agreement to identify any potential corruption and risk associated with the party through their business practices and reputations.

TAHMO will conduct a background check on the third party including its owner, key personnel, and any companies affiliated with it by looking at any history of bribery, corruption, or any fraudulent activities.

Third parties or partners will be screened for any blacklisting in any relevant watchlists, sanctions lists, and public databases to identify any red flags or indications of corruption. Their anti-corruption and anti-bribery policies will be evaluated to ensure alignment with TAHMO standards.

TAHMO will establish a monitoring system and follow up with third parties to detect any changes in the risk of their business practices.

Reporting mechanism

Any corruption and bribery case reported will be handled with confidentiality and anonymity. The report will remain anonymous, and the identity of any staff or person who submits a report will be kept confidential.

The complaints@tahmo.org email is provided and made public to every staff and the general public who may need to report any corrupt or fraudulent behavior. This email is accessible to everyone via www.tahmo.org.

Every staff, contractor, and subcontractor will be educated on the importance of using the complaints email and be informed that this will be treated with respect and confidentiality.

When reporting, all forms of bribery or corruption should be in a written form with documented evidence including dates when it first started if available with witnesses.

Anyone reported or accused of corruption will be properly investigated by the HR, Admin, or a selected external party with experience in handling such cases.

Consequences of engaging in corruption

TAHMO will not tolerate any form of corruption by its employees including, the CEO, Directors, managers, contractors, and subcontractors and this will result in disciplinary actions and a breach of the code of conduct. Consequences that may apply to all responsible personnel include termination of contracts and employment contracts, penalties, demotion, and imprisonment.

Actions to be taken when confronted with corruption

In any circumstances that a TAHMO employee has been asked to receive a bribe or engage in a corrupt activity, he/she should take the following action:

• Kindly and politely refuse to go on with the request or corrupt activity.
• Report to management using the complaints email address immediately so the action(s) can be taken.

Policy implementation

Training and awareness will be given to all employees, stakeholders, contractors interns, and subcontractors about the TAHMO anti-corruption policy and the consequences of violating it.

Senior management will be committed to setting good examples of ethical behaviors and responsibilities to uphold the policy.

This policy will be periodically monitored and updated with consultations with legal experts and compliance professionalism to ensure its effectiveness.