How does Oxfam Novib ensure that project funds are spent and used in line with integrity?
Integrity and accountability are at the heart of our work and must therefore be a part of our DNA. This means that we are accountable for our actions, for spending our donor money wisely and for adhering to moral and ethical principles.
Corporate social responsibility
Oxfam Novib strives for a just world, without poverty. Minimizing our own environmental impact is part of this effort. We comply with the Dutch government’s sustainability criteria for all our purchases and acquisitions and, wherever possible, go beyond. For example, we ask suppliers to show us what happens in their supply chains and we enquire about their policies on human rights, the environment and the treatment of their staff. All suppliers must comply with the Oxfam Ethical Purchase Policies. By signing these conditions, as part of the agreement, suppliers are both morally and legally obliged to adhere to our ethical and environmental standards.
Code of Conduct
Every Oxfam employee is obliged to sign an internal Code of Conduct. Sexual abuse, sexual harassment, misconduct and fraud are part of that Code of Conduct. In October 2017, the Oxfam International code of conduct Code of Conduct was tightened. All Oxfam Novib staff members will (re)-sign this amended Oxfam Code of Conduct before 1 March 2018.
Child Protection Policy
Oxfam’s child protection policy is a guideline which clearly emphasizes the rights children have to be protection from abuse and exploitation. It sets out the responsibility Oxfam has to ensure that all employees, volunteers, contractors and partners are given guidance about the standards of behavior and practice required of them at all times when they are in contact with children. The policy also formulates guidelines for incorporating Child Protection into programme and other work, as well as internal and external reporting procedures and what the steps are when the policy is breached.
Anti-bullying and harassment policy
Oxfam’s anti-bullying and harassment policy sets out guidelines to ensure that everyone working for Oxfam (employees and volunteers) are treated with dignity, fairness and respect. In our commitment to provide a workplace that is free from bullying and harassment, the guidelines provides definitions of bullying and harassment, as well as what steps to take for employees when faced with bullying and harassment.
The Oxfam security policy aims to record and communicate the guiding principles and responsibilities that form the governing framework for security risk management. The policy provides managers and staff direction and guidance to enable Oxfam’s programme objectives to be effectively implemented while at the same time protecting Oxfam’s employees, reputation and assets from harm.
Fraud prevention and monitoring As part of our approach to integrity, Oxfam Novib is committed to preventing and fighting all types of fraud and corruption within our organization and the partner organizations we work with. To enable us to live up to this commitment, Oxfam Novib has a counter fraud and corruption strategy, which includes:
- Policies against bribery and other types of corruption, and holding employees and partner organizations accountable for reporting incidents.
- Maintaining, updating and enforcing additional policies and procedures for countering corruption within identified risk areas.
- Holding employees and partner organizations accountable for reporting suspected cases of corruption, providing them with suitable channels of communication and ensuring that sensitive information is treated appropriately.
- Investigating instances of alleged fraud and corruption and taking firm action against any employee or partner organization involved in proven corruption.
- Strengthening partner organizations to improve their accountability systems and procedures.
Quality Management System
To ensure the quality of Oxfam Novib as an organization, a Quality Management System is in place, including various external and internal quality standards. We are firmly committed to doing our utmost to meet these standards, to enable the organization to perform in an efficient, professional and transparent manner. In order to achieve this, we adhere to a range of standards and tools, such as internal and external audits, as well as adhering to external standards.
Oxfam Novib uses external audits as well as internal audits to monitor compliance and continuous improvement. In 2016/17, we audited our country offices in Tunisia (Maghreb region), Occupied Palestinian Territory and Israel, Nigeria, Mali, Mozambique, Burundi, Niger, Somalia and Vietnam. We also conducted a project audit in Greece. All The Hague units and sub-units will be audited in 2017/18.
Country offices and partner organizations are supported in following up on audit results. In addition, project audits were held of a sample of all projects, covering internal control processes around approvals and transfers to partner organizations. Internal audits follow the main rules and regulations for compliance with institutional donors.
In 2015/16 Oxfam Novib, in cooperation with Mazars (Oxfam Novib’s accountant), established a new and improved audit approach for internal audits. In 2016/17, this new approach was embedded in the auditing of our country offices as well as of our partner organizations. The approach has an increased focus on areas of risk and is based on a clearly determined level of assurance we as an organization require. This strategy will also be the foundation for the internal audits planned for 2017/18. Starting in 2017/18, Oxfam Novib will internally audit all country offices, regional platforms and The Hague (sub-)units once every two years. If deemed necessary, more frequent audit visits will be planned, based on a risk analysis carried out per country.
ISO 9001:2015: Oxfam Novib is measured against a Quality Management System standard defined by the International Organization for Standardization (ISO) 9001. Our ISO 9001 certificate is based on the framework of standards set in 2015, which features the high level structure as its new foundation. Oxfam Novib is audited against these standards on an annual basis.
Partos: Oxfam Novib also complies with the Partos standard for the development cooperation sector in the Netherlands. In 2016/17 we were audited against the special Partos standard derived from the ISO 9001:2015 framework of standards. We now have the Partos Seal of approval based on the latest requirements. In addition, and as a member of Partos, Oxfam Novib is committed to upholding the agreements laid down in the Partos Code of Conduct, in the interests of effective collaborative development.
Central Bureau on Fundraising (CBF): The CBF is an independent foundation that has monitored fundraising by charities in the Netherlands since 1925. In 2016/17, Oxfam Novib was successfully reassessed for the CBF Seal of approval; we will be reassessed once every three years. This latest reassessment was performed based on the new qualification system from CBF introduced in 2016.
Goede Doelen Nederland: We are party to and comply with the code of conduct for members of the Dutch charity sector’s association Goede Doelen Nederland, on standards of behavior and actions for fundraising organizations.
Code Wijffels: The ‘code Wijffels’, named after the chairman of the committee that designed it, has been the governance code for charities in the Netherlands since 2005. It provides a set of checks and balances in order to maintain public trust in charities. In line with this code, Oxfam Novib has separate organs for governance and supervision, arranged in the statutes and the regulations governing the Board of Directors and the Board of Supervisors. The Board of Directors governs the foundation.
International Aid Transparency Initiative (IATI): Oxfam Novib complies with the IATI standard for open data and transparency, and hosts the Atlas website (atlas.oxfamnovib.nl) to digitally disclose information on all our projects. By sharing our project information and making our data accessible, we aim to connect with organizations and individuals similar to us who are committed to transparency. We add value by providing insight into our work, share knowledge, join forces, and compare projects and work done by different organizations. This way, we can improve our responses and avoid duplication of efforts.
INGO Accountability Charter and the Global Reporting Initiative (GRI): Oxfam Novib is a member of the INGO Accountability Charter, which is committed to a high standard of transparency, accountability and effectiveness. The Charter defines standards in all areas of NGO work, such as governance, program effectiveness, and fundraising. Signing up to these standards involves annual reporting on commitments using the Global Reporting Initiative (GRI) NGO Sector Supplement, a reporting tool developed to meet the needs of NGOs for annual reporting. The standards relate to how organizations should report and on which topics, mainly with regard to Corporate Social Responsibility issues.
Oxfam Novib works in a complex, multi-level and dynamic environment. Working in such an environment, it is of a paramount importance to identify risks on different levels within the organization and manage them adequately. Risk management throughout the organization is therefore considered a high priority. Oxfam Novib has integrated risk management at all organizational levels, as well as in our relationships with our partner organizations. Oxfam Novib’s risk policy is based on the internationally recognized management model for risk management, COSO (Committee of Sponsoring Organizations), and on the risk management policy of the Oxfam confederation.
Risks at the organizational level: the Risk Register
Oxfam Novib’s Risk Register identifies potential internal and external risks, classifies the risks and defines and monitors mitigation measures. We renew our risk register on an annual basis and, in addition, update it biannually. Both renewal and update are carried out in close consultation with the management team and the Board of Directors, before being submitted to (the financial committee of) the Board of Supervisors. Based on the risks (and sub-risks) mentioned in the risk registers, mitigation measures are determined which are monitored through the Balanced Score Card and through the annual update of the register. In some cases we create internal project teams to deal with these risks.
Risks at the country level: control framework
All country offices have separate (financial) risk profiles. Wherever and whenever needed, Oxfam Novib supports its country offices from our office in The Hague. We minimize risks by providing support and training, and through a solid control framework. Furthermore, through the internal audit cycle (as explained above), all main risk areas are tested and checked regularly. When audits prove that risks are not mitigated well enough, we draft an action plan, provide support and plan a follow-up.
Risks at the project level: partner assessments
Risks within the projects we execute are managed throughout the entire process. The Oxfam Novib Project Cycle describes our ways of working and the checks and balances we have implemented. When a (local) partner organization implements a project, a financial and governance risk assessment is carried out as part of the assessment of this partner. A uniform risk assessment method called ‘Risk Assessment Method Oxfam Novib’ (RAMON) is mandatory whenever we take on a new partner organization and an annual update of the findings is obligatory. We manage risks regarding our partners through this tool and through periodical reporting and field visits. As our country offices manage our local partners, potential risks are carefully managed from the country itself. Payments to partner organizations are done only when all contractual conditions have been fulfilled.
Risks at the personal level: security
As we work in high-risk, conflict-sensitive and fragile areas, the safety of our employees is paramount. Oxfam Novib provides mandatory security training for all travelling employees, a global toolkit for security management, security briefings in-country and constant monitoring of the security situation in designated areas. If a security situation does not allow our staff to work in a safe way, our projects continue to be closely monitored from another location. In order to ensure a safe working environment for all Oxfam Novib employees, the organization complies with an anti-bullying and anti-harassment policy in addition to the Code of Conduct. Oxfam Novib also provides in-house confidential counselors, who are selected and approved by the Board of Directors and the Works Council.