Policies

Anti-Corruption Policy

Zero tolerance, defined precisely: what the coalition prohibits, how it screens, how it investigates, and what happens when integrity fails.

100%
of counterparties integrity-screened before commitment
0
tolerance threshold for prohibited practices
24/7
confidential reporting channels, all languages of operation

Corruption is a tax levied by the powerful on the poor, and a development institution that tolerates it in its own operations finances the very extraction it exists to end. The coalition therefore operates a zero-tolerance framework — a phrase this policy defines precisely, because zero tolerance without definitions is a slogan. It prohibits specific conduct, screens for it before capital moves, audits for it while capital is at work, and sanctions it when it is found, regardless of who is involved.

Prohibited practices

The coalition prohibits five practices across everything it finances and everyone it employs, using definitions harmonised with those of the major multilateral institutions.

  • Corruption — offering, giving, receiving, or soliciting anything of value to improperly influence the actions of another party.
  • Fraud — any act or omission, including misrepresentation, that knowingly or recklessly misleads to obtain a financial or other benefit or to avoid an obligation.
  • Coercion — impairing or harming, or threatening to impair or harm, any party or its property to improperly influence its actions.
  • Collusion — an arrangement between two or more parties designed to achieve an improper purpose, including improperly influencing the actions of another party.
  • Obstruction — destroying, falsifying, or concealing evidence material to an investigation, or threatening those who provide it.

Where the policy reaches

The policy applies to coalition staff and officials at every grade, to counterparties and their beneficial owners, to contractors and sub-contractors in coalition-financed procurement, and to the coalition’s own vendors.

Reach is contractual, not rhetorical: every financing agreement carries integrity covenants, audit rights, and termination triggers tied to the prohibited practices. A counterparty that will not sign the covenants does not receive coalition capital, whatever the strategic appeal of the transaction.

Prevention before punishment

The framework is weighted toward stopping corruption before it happens. Every counterparty is screened — identity, beneficial ownership, sanctions exposure, and adverse-media history — before commitment, and re-screened on a risk-based cycle for the life of the engagement.

Procurement under coalition financing follows open, documented, criteria-based competition with published awards. Staff in exposed roles receive annual integrity training and rotate periodically. Gifts and hospitality above a nominal threshold are declared to a public-by-default register, and conflicts of interest are declared before — not after — the decision they touch.

Reporting and protection

Anyone — staff, counterparty employee, project-affected person, member of the public — may report suspected corruption through confidential channels that operate around the clock in the coalition’s languages of operation, with anonymity respected where requested.

Retaliation against a reporter acting in good faith is itself a sanctionable offence, treated with the same severity as the conduct reported. The coalition’s experience is unambiguous: institutions that punish messengers stop receiving messages, and then corruption proceeds unreported. Protection of reporters is therefore not generosity; it is the mechanism that keeps the whole framework supplied with signal.

Investigation and sanctions

Reports are triaged by the integrity office, which investigates independently of the operational teams whose work it examines and reports findings to the audit committee of the Governing Council.

Substantiated findings carry consequences calibrated to the conduct: for staff, discipline up to dismissal and referral to national authorities; for counterparties, remediation plans, suspension, debarment from future coalition financing, and contract termination with recovery of funds. Debarments are published. The coalition also honours cross-debarment with peer institutions, so that an actor barred by one multilateral cannot simply move to the next.

Accountability for the framework itself

The integrity office publishes annual statistics — reports received, investigations opened, findings, and sanctions — so that the framework’s activity is itself auditable from outside.

The policy is reviewed every two years against evolving international standards, and every review is published with a summary of what changed and why. A zero-tolerance policy the public cannot inspect is a claim; this one is designed to be a record.

Suspected corruption in anything the coalition finances can be reported through the accountability page. Every report is read, every report is logged, and no report is ignored.

Engagement
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