05/05/2026
RECO's Anti-Fraud Policy is part of a broad range of RECO policies and procedures that form RECO’s
internal control framework and that are designed, as a whole, to ensure that RECO resources are used
optimally and only for the intended purposes.
The Anti-Fraud Policy affirms RECO’s long-standing zero tolerance for all forms of fraud and corruption
and outlines the steps to be taken in response to good faith reports of possible fraud.
Any act of fraud or corruption in RECO’s activities depletes funds, assets, and other resources necessary
to fulfill RECO’s mandate. Fraudulent and corrupt practices can also seriously damage RECO’s reputation
and diminish donors’ trust in its ability to deliver results in an accountable and transparent manner.
Furthermore, it may affect staff and personnel effectiveness, motivation and morale, and impact on RECO’s
ability to attract and retain a talented work force.
1.1. Zero Tolerance
RECO has zero tolerance against fraud and corruption. “Zero- tolerance” means that RECO will pursue
all allegations of fraudulent acts and that appropriate disciplinary measures will be applied if wrongdoing
is established. In addition, certain matters may be referred to authorities for prosecution.
Despite its zero-tolerance policy, the organization also acknowledges that a residual risk of fraud or corruption
will always exist, no matter how hard the organization fights it. The objective of this Anti-Fraud Policy is
therefore to reduce fraud and corruption to an absolute minimum through adequate and systematic
deterrence, prevention, detection, and response actions.
1.2. Roles and Responsibilities
RECO representatives are responsible stewards of funds and assets under RECO’s care. They play a vital
role in the deterrence, prevention and detection of fraud, misconduct, corruption, waste, and abuse at all
levels of the organization. Representatives have a duty to report actual or suspected fraud or corruption.
The Chief Executive Officer (CEO) is ultimately accountable for the functioning system of internal controls.
The design, establishment, and implementation of appropriate frameworks of internal controls is delegated
to the Director of Finance and Operations. Responsibility over the management of resources within their
respective Directorate is delegated to the Directors (together referred to as the Leadership Team).
It is the responsibility of the Leadership Team to set the tone by behaving ethically; creating a positive
work environment; hiring and promoting Representatives who are competent and have the right work ethic;
implementing the Code of Conduct; ensuring that fraud controls are implemented; and by taking
disciplinary actions, when necessary, within the parameters established by policies.
Through their delegated authority, Directors are responsible and accountable for ensuring that all measures
aimed at preventing, detecting, and responding to fraud, misconduct and corruption are in place in their
Directorate and that an appropriate and robust internal control environment is maintained.
This includes:
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Assessing and reporting on fraud risks periodically and at the start of new projects.
Ensuring that all anti-fraud measures are in place and that their effectiveness is monitored.
Raising awareness of fraud risks and ensuring that all Representatives are vigilant.
Encouraging Representatives to report any suspected fraud or misconduct without fear of
retaliation.
Assisting in the recovery of loss related to proven fraud.
Informing, without delay, the Leadership Team of breaches of this Policy.
The Internal Audit and Compliance Officer has responsibility for conducting or coordinating investigations
in the organization. The Officer will consider fraud and corruption red flags and risk factors in audit planning
and reporting, consistent with applicable auditing standards. Proactive investigations may also be initiated
by internal audit, without awaiting the receipt of allegations.
The Executive Board will be periodically informed about the prevention, detection, and response
mechanisms, as well as about fraud and corruption incidents, if any. This promotes the effectiveness of the
function and provides a forum to discuss internal control, fraud, and corruption.
1.3. Internal Control Framework
This Anti-Fraud Policy is a cornerstone of the organization’s internal control framework, which is further set
out in the Finance and Accounting Policy. A strong internal control system, where policies and procedures
are enforced, internal controls are appropriately implemented, and staff members, non-staff personnel,
vendors, implementing partners and other parties are informed about fraud and corruption and its
consequences, can curtail fraud and corruption. This policy should be read in conjunction with the related
Code of Conduct. The ultimate objective and principle of the Internal Control Framework set up in these
documents and through associated processes is to nurture a culture of ethics, integrity, transparency, and
accountability at RECO and thereby to enhance trust in RECO, both internally and externally.
1.4. Incident Reporting
Everybody must speak up if and when they suspect or witness fraudulent activities or corruption within
RECO, its partner organizations or another party affecting the RECO. No matter who is involved, senior or
junior staff, and no matter the materiality or the context.
All incidents of fraud and corruption are to be reported, will be assessed and, as appropriate, investigated.
RECO will rigorously pursue disciplinary and other actions against perpetrators of fraud, including
recovery of financial loss suffered by RECO.
1.5. Scope and Application
RECO has zero tolerance for fraud and corruption, meaning that RECO staff members, non-staff
personnel, vendors, implementing partners and responsible parties are not to engage in fraud or corruption.
This Policy applies to all activities and operations of RECO, including projects and programs funded by
RECO as well as those implemented by RECO. This Policy aims to prevent, detect, and address acts of
fraud and corruption involving:
