Anti-Fraud and Anti-Corruption Policy - Bangladesh Nature Foundation

Bangladesh Nature Foundation (BNF)

Head Office: Sayman Road, Cox’s Bazar-4700, Bangladesh

Established: 2010

Applies To: General Committee, Executive Committee, management, employees, project personnel, consultants, researchers, volunteers, interns, contractors, suppliers, partners, and representatives of BNF

Effective Date: 01 January 2010

Last Updated: 16 September 2026

1. Introduction

Bangladesh Nature Foundation (BNF) is committed to conducting all of its activities with integrity, accountability, transparency, professionalism, and responsible stewardship of resources. As a conservation and development organization, BNF may receive and manage funds and other resources from donors, development partners, institutions, individuals, grants, project partners, and other legitimate sources. These resources are entrusted to BNF for the achievement of approved organizational and project objectives. BNF recognizes that fraud, corruption, bribery, financial misconduct, conflicts of interest, misuse of organizational authority, procurement irregularities, diversion of project resources, and other forms of dishonest conduct can undermine conservation, community development, research, livelihoods, environmental protection, and public trust.

BNF therefore adopts a strong organizational commitment to preventing, detecting, reporting, investigating, and responding appropriately to fraud and corruption. This Anti-Fraud and Anti-Corruption Policy establishes the standards and principles that govern BNF’s approach to preventing financial and non-financial misconduct. It applies to BNF’s governance, management, employees, projects, finances, procurement, research, partnerships, community activities, fundraising, and other operations.

2. Purpose of the Policy

The purposes of this policy are to:

prevent fraud and corruption;
protect BNF’s funds, property, assets, information, and reputation;
establish clear standards of ethical conduct;
promote responsible financial management;
strengthen procurement integrity;
prevent bribery and improper payments;
identify and manage fraud and corruption risks;
provide clear reporting mechanisms;
protect people who report concerns in good faith;
establish appropriate investigation and response procedures;
ensure appropriate accountability for misconduct;
strengthen donor and partner confidence;
protect beneficiaries and communities from exploitation;
promote transparency in project implementation;
support accurate financial and programmatic reporting;
strengthen internal controls;
promote responsible governance; and
support continuous improvement in BNF’s systems and procedures.

3. Scope

This policy applies to all BNF activities, including:

organizational governance;
financial management;
accounting;
budgeting;
procurement;
purchasing;
contracting;
grant management;
fundraising;
donations;
project implementation;
community development;
livelihood programs;
conservation programs;
environmental activities;
research;
monitoring and evaluation;
recruitment;
payroll;
travel;
field activities;
asset management;
partnership management;
consultancy;
training;
workshops;
events;
publication activities;
information management;
digital systems; and
other activities conducted by or on behalf of BNF.

4. Persons Covered by the Policy

This policy applies to:

General Committee members;
Executive Committee members;
President;
Vice President;
General Secretary;
Treasurer;
Executive Director;
managers;
employees;
project personnel;
field staff;
researchers;
consultants;
volunteers;
interns;
contractors;
suppliers;
service providers;
trainers;
implementing partners;
partner organizations;
representatives; and
other persons acting on behalf of BNF.

The policy applies regardless of a person’s position, seniority, contractual status, or relationship with BNF.

5. Core Principles

BNF’s anti-fraud and anti-corruption framework is based on the following principles.

5.1 Integrity

BNF expects all persons acting on its behalf to act honestly and ethically.

5.2 Zero Tolerance for Deliberate Fraud and Corruption

BNF does not accept deliberate fraud, bribery, corruption, theft, embezzlement, falsification, or intentional diversion of organizational resources.

5.3 Accountability

Individuals are responsible for their decisions, actions, financial responsibilities, and use of organizational resources.

5.4 Transparency

BNF seeks to maintain appropriate transparency in financial, procurement, project, and organizational activities.

5.5 Segregation of Duties

Where reasonably practical, key financial and operational responsibilities should be separated to reduce opportunities for fraud and error.

5.6 Proportionality

Controls should be proportionate to the financial, operational, project, and organizational risks involved.

5.7 Confidentiality

Fraud and corruption concerns should be handled sensitively and information should be shared only with persons who have a legitimate need to know.

5.8 No Retaliation

BNF will not tolerate retaliation against individuals who raise genuine concerns in good faith.

5.9 Fairness

Allegations should be assessed objectively and persons accused of misconduct should be treated fairly during review and investigation.

5.10 Continuous Improvement

BNF will seek to strengthen internal controls based on identified risks, incidents, audits, investigations, and organizational learning.

6. Definition of Fraud

For this policy, fraud generally refers to intentional deception, concealment, misrepresentation, or dishonest conduct undertaken to obtain an unauthorized benefit, cause another party to suffer a loss, or improperly influence a decision. Fraud may involve:

money;
property;
services;
project resources;
information;
documents;
organizational opportunities;
benefits;
procurement;
employment;
research;
reporting; or
other organizational resources.

Examples include:

false expense claims;
fictitious invoices;
falsified receipts;
manipulation of accounts;
false beneficiary records;
fabricated project activities;
unauthorized diversion of funds;
theft;
false qualifications;
forged signatures;
falsified attendance;
fabricated research data;
deliberate manipulation of monitoring data; and
unauthorized use of organizational assets.

7. Definition of Corruption

Corruption generally refers to the misuse of entrusted power, authority, position, resources, or influence for an improper personal, financial, organizational, or third-party benefit. Corruption may include:

bribery;
kickbacks;
improper commissions;
extortion;
favoritism;
nepotism;
improper influence;
abuse of authority;
manipulation of procurement;
improper gifts;
conflicts of interest that are deliberately concealed; and
other forms of dishonest influence.

8. Bribery

Bribery is prohibited. No person acting for BNF may:

offer a bribe;
promise a bribe;
request a bribe;
accept a bribe;
authorize an improper payment;
facilitate a bribe; or
conceal a bribe.

A bribe may involve money or anything of value offered or received to improperly influence a decision or action.

9. Kickbacks

A kickback is an unauthorized payment, benefit, commission, gift, or other advantage provided in exchange for favorable treatment. BNF personnel must not:

demand kickbacks from suppliers;
accept supplier commissions;
arrange secret payments;
manipulate contracts in exchange for personal benefits; or
facilitate undisclosed financial arrangements.

10. Facilitation Payments

BNF personnel should not make or authorize unofficial payments intended to obtain or accelerate routine governmental, administrative, regulatory, or other services where such payments are improper. Where personnel encounter a situation involving a demand for an unofficial payment, they should report the matter through an appropriate organizational channel.

11. Extortion and Coercive Payments

BNF recognizes that personnel may sometimes face threats or coercion. Where an individual is threatened with immediate harm and makes a payment under genuine duress, the individual should report the incident as soon as reasonably possible. Such reporting allows BNF to assess the circumstances and relevant risks.

12. Gifts and Hospitality

Gifts, hospitality, meals, travel, discounts, favors, or entertainment may create actual or perceived conflicts of interest. BNF personnel must not accept or provide benefits where the purpose or effect is to improperly influence a decision. Particular caution should be exercised in relation to:

procurement;
recruitment;
contract awards;
grants;
donor relations;
regulatory processes;
inspections;
research partnerships; and
project beneficiary selection.

13. Permissible Gifts

A modest customary gift may be acceptable where:

it is lawful;
it is not intended to influence a decision;
it does not create an obligation;
it is consistent with organizational practice; and
accepting it would not reasonably create an appearance of impropriety.

Where doubt exists, personnel should seek guidance or decline the benefit.

14. Conflicts of Interest

A conflict of interest may arise where personal interests could improperly influence organizational decisions. Potential conflicts may involve:

family members;
close personal relationships;
businesses;
suppliers;
contractors;
consultants;
research collaborators;
financial interests;
outside employment;
investments;
community relationships; or
other personal connections.

Conflicts must be disclosed and appropriately managed. BNF’s Conflict of Interest Policy should be applied alongside this policy.

15. Nepotism and Favoritism

BNF does not permit improper favoritism based on personal relationships. Personnel must not manipulate:

recruitment;
procurement;
beneficiary selection;
project opportunities;
consultancy assignments;
promotions;
grants; or
other organizational decisions

for the improper benefit of relatives, friends, associates, or other connected persons.

16. Fraudulent Financial Claims

Personnel must not submit false or misleading:

travel claims;
accommodation claims;
meal claims;
reimbursement requests;
invoices;
receipts;
salary records;
timesheets;
procurement documents; or
other financial documentation.

Claims should reflect genuine expenses incurred for authorized organizational purposes.

17. Fictitious Transactions

BNF personnel must not create or record transactions that did not actually occur. Examples include:

fictitious purchases;
fictitious training participants;
fictitious beneficiaries;
fictitious travel;
fictitious consultancy;
fictitious suppliers;
fictitious project activities; or
false service delivery.

18. Financial Record Integrity

Financial records must be:

accurate;
complete;
appropriately authorized;
supported by relevant documentation;
maintained securely; and
prepared in accordance with applicable organizational procedures.

Personnel must not deliberately manipulate financial records to conceal misconduct.

19. Accounting Manipulation

Examples of prohibited conduct include:

concealing liabilities;
overstating assets;
understating expenses;
falsifying income;
moving expenses between projects to conceal overspending;
creating false accruals;
manipulating dates;
altering records without authorization; or
concealing unauthorized transactions.

20. Cash Management

Cash should be handled with appropriate controls. Where cash is used, BNF should seek to maintain:

authorized cash limits;
appropriate documentation;
receipts;
cash counts;
reconciliations;
authorization procedures;
secure storage; and
segregation of duties where reasonably practical.

21. Bank Accounts

BNF bank accounts should be used only for authorized organizational purposes. Personnel must not:

use organizational accounts for unauthorized personal transactions;
conceal transactions;
create unauthorized accounts;
transfer funds without appropriate authority; or
share banking credentials improperly.

22. Electronic Payments

Electronic payments should be appropriately:

authorized;
documented;
verified;
recorded; and
reconciled.

Where reasonably practical, payment initiation and approval should be separated.

23. Payroll Integrity

Personnel responsible for payroll must ensure that salary and personnel records are accurate.

Fraudulent payroll practices may include:

fictitious employees;
false attendance;
unauthorized salary payments;
unauthorized allowances;
duplicate payments;
manipulation of overtime;
unauthorized bonuses; or
diversion of salaries.

24. Recruitment-Related Corruption

Personnel must not demand or accept money, gifts, sexual favors, personal services, or other improper benefits in exchange for:

employment;
internships;
volunteer opportunities;
promotions;
training;
recommendations; or
other organizational opportunities.

25. Procurement Integrity

Procurement must be conducted fairly, transparently, and according to approved procedures. Personnel involved in procurement must not:

manipulate specifications to favor a supplier;
create false competition;
share confidential bid information improperly;
accept kickbacks;
favor connected suppliers without disclosure;
split purchases to avoid approval thresholds;
create fictitious suppliers;
submit false quotations;
collude with bidders; or
approve unauthorized purchases.

26. Supplier Selection

Supplier selection should be based on legitimate criteria such as:

quality;
price;
technical suitability;
capacity;
reliability;
delivery requirements;
relevant experience; and
organizational needs.

Personal relationships must not improperly determine supplier selection.

27. Bid and Quotation Manipulation

Personnel must not:

fabricate quotations;
obtain sham quotations;
manipulate bids;
provide confidential competitor information;
alter supplier documents improperly;
suppress legitimate bids; or
coordinate secretly with bidders to obtain an improper result.

28. Contract Management

Personnel responsible for contracts should ensure that:

contracts are appropriately authorized;
services are actually delivered;
invoices correspond to actual services or goods;
contract variations are properly approved;
payments are supported;
deliverables are verified; and
records are maintained.

29. Supplier Due Diligence

Where proportionate to the risk, BNF may assess:

supplier identity;
ownership;
relevant qualifications;
experience;
capacity;
conflicts of interest;
reputational concerns; and
ability to deliver the required goods or services.

30. Asset Management

BNF assets must be properly recorded, maintained, and used. Assets may include:

vehicles;
computers;
cameras;
research equipment;
laboratory equipment;
field equipment;
furniture;
communication devices;
project materials;
property; and
other organizational resources.

Personnel must not steal, sell, transfer, damage, or privately use organizational assets without authorization.

31. Disposal of Assets

Disposal of organizational assets should be:

authorized;
documented;
transparent;
appropriately valued where relevant; and
consistent with applicable organizational requirements.

Personnel must not privately acquire organizational assets through unauthorized disposal arrangements.

32. Inventory Management

Where BNF maintains inventories, records should be periodically checked against physical assets. Discrepancies should be investigated and appropriately documented.

33. Vehicle Misuse

BNF vehicles must not be:

used for unauthorized private business;
transferred to unauthorized persons;
used to transport prohibited goods;
used for personal commercial activities; or
used in a manner that creates unreasonable organizational risk.

34. Fuel and Travel Fraud

Personnel must not falsify:

mileage;
fuel purchases;
travel dates;
destinations;
vehicle use;
accommodation;
transportation costs; or
travel-related expenses.

35. Project Fund Integrity

Project funds must be used for approved purposes. Personnel must not:

divert funds between unauthorized purposes;
spend project funds for personal use;
create false project expenditures;
inflate beneficiary numbers to justify spending;
fabricate project activities; or
conceal significant financial deviations.

36. Donor Funds

Where BNF receives donor funding, personnel must follow applicable:

grant agreements;
approved budgets;
donor conditions;
reporting requirements;
organizational procedures; and
applicable regulatory requirements.

Donor resources must not be used for unauthorized personal benefit.

37. Grant Management

Grant-related fraud may include:

false proposals;
fabricated beneficiaries;
inflated budgets;
false expenditure reports;
fabricated outputs;
unauthorized sub-grants;
false procurement;
concealment of conflicts; or
misrepresentation of project performance.

38. Fundraising Integrity

BNF fundraising activities must be conducted honestly. Personnel must not:

fabricate project stories;
invent beneficiaries;
falsely claim donor relationships;
misrepresent project costs;
exaggerate results deliberately;
use donations for unauthorized purposes; or
divert donations.

39. Donations

Donations should be:

properly recorded;
appropriately acknowledged;
used for legitimate purposes;
protected from diversion; and
managed according to relevant restrictions.

Where a donation is designated for a specific purpose, BNF should respect applicable restrictions and document any authorized changes.

40. Community-Level Financial Management

Where community groups receive or manage project funds, BNF should establish appropriate controls proportionate to the risk. These may include:

transparent selection;
documented approvals;
receipts;
community-level records;
reporting;
reconciliation;
monitoring; and
appropriate community oversight.

41. Beneficiary Assistance

Personnel must not:

charge unauthorized fees;
demand payments;
demand gifts;
demand personal favors;
divert assistance;
manipulate beneficiary lists; or
retain resources intended for beneficiaries.

42. Community Procurement

Where community procurement is supported by BNF, personnel must not manipulate community purchasing decisions for personal gain.

43. Bribery in Community Activities

Project personnel must not request money, gifts, labor, services, sexual favors, or other personal benefits in exchange for:

inclusion in a project;
training;
assistance;
livelihood opportunities;
equipment;
employment;
grants; or
other legitimate project benefits.

44. Research Integrity and Fraud

Fraud can also occur in research. BNF researchers must not deliberately:

fabricate data;
falsify observations;
manipulate results;
invent participants;
falsify fieldwork;
fabricate publications;
manipulate images;
falsify sampling;
misrepresent research outputs; or
submit false reports.

45. Research Funding

Research funds must be used for authorized purposes. Researchers must accurately report:

expenditure;
fieldwork;
sampling;
personnel;
equipment;
travel;
research outputs; and
other funded activities.

46. Consultancy Integrity

Consultants working for BNF must provide genuine services and deliverables. Consultants must not:

submit false invoices;
fabricate work;
subcontract without authorization;
misrepresent qualifications;
manipulate deliverables; or
provide kickbacks.

BNF personnel must not create fictitious consultancy arrangements to divert funds.

47. Training and Workshop Fraud

Training and workshop records should accurately reflect:

participants;
dates;
venue;
facilitators;
materials;
expenditure; and
activities conducted.

Personnel must not fabricate attendance or expenses.

48. Beneficiary Data Fraud

Personnel must not intentionally:

create fictitious beneficiaries;
duplicate beneficiaries to inflate numbers;
falsify eligibility;
manipulate demographic information; or
submit false beneficiary reports.

49. Monitoring and Evaluation Integrity

Monitoring and evaluation data must not be deliberately manipulated to create misleading project results. Personnel should report significant limitations and problems appropriately.

50. Reporting and Performance Data

BNF reports must accurately distinguish between:

planned activities;
completed activities;
ongoing activities;
estimated results;
verified results;
outputs; and
outcomes.

Deliberate misrepresentation of project performance may constitute misconduct.

51. Conflict of Interest in Procurement

Anyone involved in procurement who has a relevant personal or financial interest should disclose it and refrain from participating in decisions where appropriate.

52. Supplier Relationships

Personnel must not secretly own, control, or financially benefit from suppliers used by BNF without appropriate disclosure and management.

53. Undisclosed Commissions

Personnel must not receive private commissions from:

suppliers;
contractors;
consultants;
recruitment agents;
service providers;
community intermediaries; or
other parties because of their BNF role.

54. Political and Institutional Influence

BNF is a non-political organization. BNF resources must not be used to make improper payments or provide unauthorized benefits to political actors, public officials, institutional representatives, or other influential persons. Personnel must not use BNF’s organizational position to obtain improper personal benefits.

55. Government Interactions

Personnel interacting with government institutions should maintain professional and transparent conduct. Personnel must not offer or accept improper benefits to influence:

approvals;
permits;
registrations;
inspections;
project permissions;
administrative processes; or
other official decisions.

56. Conflict of Interest and Recruitment

Individuals involved in recruitment must disclose relevant personal relationships or interests and avoid improperly influencing recruitment outcomes.

57. Payroll and Attendance

Personnel must accurately record:

attendance;
leave;
overtime;
field assignments;
travel;
working days; and
other information relevant to compensation.

Managers should review payroll-related information appropriately.

58. Expense Verification

Expenses should be verified against:

receipts;
approved travel;
project activities;
budgets;
authorization;
relevant dates; and
supporting documentation.

59. Segregation of Duties

Where reasonably practical, BNF should separate:

authorization;
custody;
recording;
verification; and
reconciliation

of significant financial transactions.

No single individual should unnecessarily control every stage of a high-risk transaction.

60. Authorization Controls

BNF should maintain appropriate authorization levels for:

expenditure;
procurement;
contracts;
payments;
asset disposal;
grants;
travel;
project changes; and
other significant organizational decisions.

61. Bank Reconciliation

Bank accounts should be reconciled periodically. Unexplained differences should be investigated and resolved.

62. Cash Reconciliation

Cash balances should be periodically reconciled against records. Material discrepancies should be documented and investigated.

63. Audit

BNF will support appropriate internal and external audit processes. Personnel must:

provide accurate records;
cooperate with auditors;
avoid withholding relevant information;
respond to legitimate audit requests; and
support corrective action.

64. Audit Independence

Where an audit is conducted, personnel should not improperly influence auditors or suppress legitimate findings.

65. Internal Controls

BNF will seek to maintain controls proportionate to its size, activities, resources, and risks. Controls may include:

authorization procedures;
segregation of duties;
reconciliations;
documentation;
approval limits;
asset registers;
procurement controls;
audits;
monitoring;
supervisory review; and
risk assessments.

66. Fraud Risk Assessment

BNF may periodically assess fraud and corruption risks. Risk assessment may consider:

financial exposure;
cash handling;
procurement;
remote field operations;
project complexity;
partner arrangements;
community-level resources;
donor requirements;
staff access;
data systems;
external pressures; and
previous incidents.

67. High-Risk Activities

Additional controls may be appropriate for:

large procurement;
cash-intensive projects;
remote field activities;
high-value contracts;
community grants;
asset purchases;
construction;
emergency activities;
complex partnerships; and
activities involving significant third-party resources.

68. Due Diligence

Where proportionate, BNF may conduct due diligence on:

partners;
suppliers;
consultants;
contractors;
grantees;
major donors;
service providers; and
other relevant counterparties.

Due diligence may consider:

identity;
ownership;
qualifications;
reputation;
conflicts of interest;
financial capacity;
relevant compliance concerns; and
ability to perform the proposed role.

69. Partner Financial Accountability

Where BNF provides resources to partners, agreements should establish appropriate requirements concerning:

authorized use;
reporting;
records;
audits;
monitoring;
fraud reporting;
safeguarding; and
corrective action.

70. Subcontracting

Partners and contractors should not subcontract significant responsibilities without appropriate authorization where the agreement requires it. Unauthorized subcontracting can create financial, safeguarding, quality, and accountability risks.

71. Financial Reporting

Financial reports should be:

accurate;
complete;
timely;
supported by records;
consistent with approved budgets; and
appropriately reviewed.

72. Budget Management

Budget deviations should be appropriately monitored. Significant deviations should be reported and managed according to applicable procedures.

73. Unauthorized Expenditure

Personnel must not intentionally incur expenditure that they know is:

unauthorized;
outside their authority;
prohibited by a grant;
contrary to an approved budget without required approval; or
intended for personal benefit.

74. Splitting Purchases

Personnel must not deliberately divide purchases into smaller transactions for the purpose of avoiding required procurement approvals or thresholds.

75. False Competition

Creating fake competing suppliers or quotations to make a predetermined supplier appear competitively selected is prohibited.

76. Collusion

Personnel must not collude with:

suppliers;
contractors;
consultants;
bidders;
partners;
beneficiaries; or
other persons

to manipulate organizational decisions or obtain improper benefits.

77. Document Forgery

Forgery or unauthorized alteration of:

signatures;
receipts;
invoices;
contracts;
approvals;
certificates;
attendance records;
research documents;
reports; or
other official records

may constitute serious misconduct.

78. Unauthorized Signature Use

Personnel must not use another person’s signature, digital approval, credentials, or authority without proper authorization.

79. Digital Financial Fraud

Personnel must not:

manipulate electronic payment records;
misuse banking credentials;
create unauthorized digital transactions;
share authentication credentials;
alter electronic accounting records improperly; or
use organizational systems to facilitate financial fraud.

80. Cybersecurity and Fraud Prevention

BNF should maintain reasonable measures to protect:

banking information;
passwords;
financial systems;
donor information;
payroll information;
procurement records;
confidential documents; and
organizational databases.

81. Personal Data and Financial Information

Financial and personal information must be handled responsibly. Personnel must not use:

beneficiary bank information;
employee information;
donor information;
supplier information; or
other sensitive financial data

for unauthorized personal or commercial purposes.

82. Misuse of Organizational Information

Confidential BNF information must not be used to:

obtain personal financial benefits;
provide unfair advantages;
assist a competing organization improperly;
manipulate procurement;
exploit beneficiaries; or
obtain unauthorized business opportunities.

83. Fraud Through Misrepresentation

Misrepresentation may include knowingly providing false information concerning:

qualifications;
experience;
project performance;
expenditure;
beneficiaries;
research;
partnerships;
funding;
assets;
organizational activities; or
other material matters.

84. Fraudulent Documentation from Third Parties

Personnel should exercise reasonable care when reviewing documents submitted by suppliers, partners, consultants, and beneficiaries. Suspected irregularities should be investigated or escalated appropriately.

85. Reporting Suspected Fraud or Corruption

Anyone may report a suspected fraud or corruption concern involving BNF. Reports may be made by:

staff;
volunteers;
beneficiaries;
community members;
suppliers;
contractors;
consultants;
partners;
donors;
researchers;
government stakeholders; or
members of the public.

A person does not need to have proof of wrongdoing before raising a good-faith concern, but reports should be based on information or circumstances that reasonably justify the concern.

86. Reporting Channels

Concerns may be reported through BNF’s designated organizational channels.

Bangladesh Nature Foundation (BNF)

Sayman Road

Cox’s Bazar-4700, Bangladesh

Website: https://bdnature.org/

Anti-Fraud / Ethics Email: info@bdnature.org

Where the concern involves the Executive Director or another senior officer, it should be directed to an appropriate governance-level channel, such as the President of the Executive Committee or another designated authority.

87. Anonymous Reporting

BNF may accept anonymous reports where practical. Anonymous reporting can be useful where the reporter fears retaliation or other adverse consequences. However, anonymity may limit BNF’s ability to:

obtain additional evidence;
clarify information;
provide feedback;
protect the reporter; or
complete an investigation.

88. Confidentiality

Reports should be handled confidentially to the extent reasonably possible. Information should be shared only with persons who have a legitimate need to know. Confidentiality does not prevent BNF from taking appropriate action or making disclosures where required or necessary.

89. Protection from Retaliation

BNF does not tolerate retaliation against a person who reports a concern in good faith. Retaliation may include:

threats;
intimidation;
harassment;
discrimination;
unfair disciplinary action;
loss of legitimate opportunities;
adverse employment treatment;
exclusion; or
other punitive conduct linked to reporting.

90. Good-Faith Reporting

A report is made in good faith where the person genuinely believes that the information indicates potential wrongdoing or risk. A concern does not need to be proven in order to be reported.

91. False and Malicious Reports

BNF recognizes the difference between:

a genuine concern that cannot be substantiated; and
a deliberately false or malicious allegation.

A person should not face retaliation simply because a good-faith concern is not ultimately proven.

Knowingly fabricating allegations or deliberately misleading an investigation may constitute misconduct.

92. Initial Assessment

When a concern is received, BNF may conduct an initial assessment to determine:

the nature of the allegation;
immediate risks;
whether financial resources may be at risk;
whether records need to be preserved;
whether safeguarding concerns exist;
whether a conflict of interest exists;
whether an investigation is appropriate; and
whether referral is necessary.

93. Immediate Protective Measures

Where necessary, BNF may take temporary measures to protect:

funds;
records;
assets;
beneficiaries;
staff;
witnesses;
complainants;
research data; or
other organizational interests.

Such measures are precautionary and should not automatically be treated as findings of wrongdoing.

94. Investigation

Where appropriate, BNF may conduct or commission an investigation. Investigations should seek to be:

objective;
proportionate;
appropriately independent;
evidence-based;
confidential;
fair; and
properly documented.

95. Independent Investigation

BNF may engage an external investigator, auditor, legal adviser, financial specialist, research specialist, or other qualified professional where:

the matter is particularly serious;
senior personnel are involved;
independence is required;
specialist expertise is necessary; or
organizational capacity is insufficient.

96. Preservation of Evidence

Personnel must not intentionally:

destroy records;
delete relevant files;
alter evidence;
conceal documents;
manipulate electronic records; or
instruct others to destroy evidence

in connection with a legitimate investigation.

97. Cooperation with Investigations

Personnel are expected to cooperate appropriately with legitimate investigations and audits.

This includes providing relevant information within their authority and preserving records.

98. Fair Treatment

BNF will seek to treat persons accused of fraud or corruption fairly. An allegation is not automatically a finding of misconduct. Persons subject to investigation should be given an appropriate opportunity to respond, subject to confidentiality, evidence preservation, safety, and investigative requirements.

99. Disciplinary and Corrective Action

Where misconduct is substantiated, BNF may take appropriate action. Possible measures include:

additional controls;
training;
formal warning;
recovery of funds;
removal of financial authority;
reassignment;
suspension;
termination;
contract termination;
partner corrective action;
referral to appropriate authorities; or
other proportionate action.

100. Recovery of Misappropriated Resources

Where resources have been improperly taken or diverted, BNF may seek appropriate recovery. Recovery measures may include:

repayment;
recovery from responsible parties where appropriate;
insurance claims;
contractual remedies;
asset recovery; or
referral to appropriate authorities.

101. Referral to Authorities

BNF may refer suspected criminal or serious misconduct to appropriate authorities where:

required;
necessary to protect people or organizational resources;
appropriate under contractual or donor requirements; or
otherwise justified.

BNF will consider relevant confidentiality and procedural requirements when making referrals.

102. Donor Notification

Where required by a grant agreement, donor condition, or other legitimate requirement, BNF may notify donors or funding partners of significant fraud or corruption concerns.

103. Partner Notification

Where relevant, BNF may notify a partner organization of serious concerns connected with jointly implemented activities, subject to appropriate confidentiality and contractual requirements.

104. Financial Recovery and Corrective Controls

Following a confirmed incident, BNF may review:

financial controls;
procurement procedures;
approval systems;
supervision;
segregation of duties;
partner controls;
documentation;
staff training; and
monitoring systems.

105. Fraud Incident Register

Where appropriate, BNF may maintain a confidential record of significant fraud and corruption incidents. Records may include:

date;
nature of concern;
project;
financial exposure;
action taken;
investigation status;
outcome;
recovery; and
corrective measures.

Access should be restricted appropriately.

106. Lessons Learned

BNF will seek to learn from significant incidents. Lessons may result in:

stronger controls;
revised procedures;
additional training;
increased supervision;
changes to procurement;
improved partner due diligence;
enhanced reporting mechanisms; or
policy updates.

107. Governance Oversight

Fraud and corruption risk is an organizational governance responsibility. The appropriate governance bodies should receive sufficient information to exercise oversight while protecting confidential case information.

108. Responsibilities of the General Committee

The General Committee may:

support organizational integrity;
oversee major governance risks;
review significant organizational issues;
support accountability; and
promote responsible management.

109. Responsibilities of the Executive Committee

The Executive Committee should:

approve relevant organizational policies;
oversee major fraud and corruption risks;
support appropriate internal controls;
review significant cases where appropriate;
ensure management accountability; and
support corrective measures.

110. Responsibilities of the Executive Director

The Executive Director should:

implement this policy;
ensure appropriate internal controls;
promote ethical conduct;
ensure reporting mechanisms are available;
respond appropriately to serious concerns;
ensure relevant records are maintained;
support investigations;
report significant matters to appropriate governance bodies; and
promote continuous improvement.

111. Responsibilities of the Finance Manager

The Finance Manager should support:

financial controls;
accounting integrity;
reconciliations;
documentation;
budget monitoring;
payment controls;
financial reporting;
audit support;
identification of irregularities; and
escalation of significant concerns.

112. Responsibilities of Project Managers

Project managers should:

monitor project expenditure;
ensure activities correspond with approved plans;
maintain appropriate documentation;
supervise project personnel;
identify unusual transactions;
review project records;
report suspected irregularities; and
ensure corrective measures are implemented.

113. Responsibilities of Procurement Personnel

Procurement personnel should:

maintain fairness;
protect confidential bid information;
document decisions;
disclose conflicts;
prevent supplier favoritism;
maintain appropriate records; and
report suspected manipulation.

114. Responsibilities of All Personnel

Every person covered by this policy is responsible for:

acting honestly;
protecting organizational resources;
following financial procedures;
reporting suspected fraud or corruption;
avoiding conflicts of interest;
refusing improper payments where reasonably safe;
protecting confidential information; and
cooperating with legitimate investigations.

115. Management of High-Risk Transactions

High-value or high-risk transactions may require additional:

approvals;
verification;
documentation;
due diligence;
independent review;
monitoring; or
audit.

116. Remote and Field Operations

BNF recognizes that field activities can create additional fraud risks due to:

geographic distance;
cash handling;
limited supervision;
emergency conditions;
local intermediaries;
transportation;
community-level transactions; and
limited access to financial institutions.

Field projects should therefore use controls proportionate to these risks.

117. Emergency Expenditure

During emergencies, rapid action may be necessary. Emergency procedures should not be used as a general mechanism for avoiding controls.

Where normal procedures cannot reasonably be followed, the transaction should be:

appropriately authorized where possible;
documented;
reviewed afterward; and
reconciled.

118. Procurement During Emergencies

Emergency procurement may use simplified procedures where authorized, but personnel must still seek to prevent:

price manipulation;
favoritism;
false suppliers;
unnecessary purchases;
inflated prices;
kickbacks; and
diversion of supplies.

119. Community Representatives and Intermediaries

Where BNF works through community leaders, local organizations, or intermediaries, responsibilities should be clearly defined. Intermediaries must not:

collect unauthorized fees;
divert benefits;
manipulate beneficiary lists;
demand personal favors; or
misrepresent BNF’s decisions.

120. Anti-Corruption in Livelihood Programs

Livelihood activities should maintain transparent processes for:

beneficiary selection;
training;
equipment distribution;
grants;
enterprise support;
market linkages;
financial assistance; and
monitoring.

121. Environmental and Conservation Activities

Corruption can undermine environmental governance and conservation. Personnel must not seek or provide improper benefits in connection with:

environmental permissions;
resource access;
conservation contracts;
field services;
biological collection;
procurement;
project approvals; or
environmental reporting.

122. Research and Publication Integrity

BNF personnel must not offer or accept improper benefits to influence:

research results;
authorship;
peer review;
publication decisions;
research access;
data interpretation; or
scientific reporting.

123. Academic and Institutional Partnerships

Personnel should maintain transparent relationships with:

universities;
research institutions;
laboratories;
academic researchers;
government institutions; and
other knowledge partners.

Improper financial or personal benefits must not influence research or institutional decisions.

124. Fraud in Publications and Communications

BNF communications must not deliberately fabricate:

project achievements;
photographs;
beneficiary stories;
statistics;
research results;
funding relationships;
partnerships; or
organizational activities.

125. Website Transparency

Information published on BNF’s website should be accurate to the best of the organization’s knowledge. Personnel responsible for website content must not knowingly publish fraudulent financial, project, research, partnership, or organizational information.

126. Public Donations and Online Fundraising

Where BNF conducts online fundraising, it should clearly communicate:

the identity of BNF;
relevant fundraising purposes;
legitimate payment channels;
appropriate terms;
contact information; and
relevant restrictions.

Personnel must not redirect donations to personal accounts or unauthorized payment channels.

127. Payment Security

Donors, beneficiaries, staff, and partners should be encouraged to use only authorized BNF payment channels. BNF personnel must not request payments to private accounts for organizational transactions without explicit and documented authorization consistent with applicable procedures.

128. Financial Privacy

Personnel must protect financial information concerning:

donors;
beneficiaries;
staff;
suppliers;
partners;
consultants; and
other stakeholders.

129. Fraud Awareness

BNF may conduct periodic awareness activities concerning:

common fraud schemes;
bribery risks;
procurement fraud;
financial controls;
reporting mechanisms;
cybersecurity;
conflicts of interest; and
safeguarding risks.

130. Training

Relevant personnel may receive training covering:

anti-fraud principles;
anti-corruption;
bribery;
procurement;
financial controls;
conflicts of interest;
reporting;
whistleblower protection;
investigations;
research integrity; and
responsible use of organizational resources.

131. Whistleblower Protection

BNF’s Whistleblower Policy should be applied to serious reports of:

fraud;
corruption;
bribery;
financial misconduct;
abuse of authority;
serious organizational wrongdoing; and
other significant misconduct.

Good-faith reporters should be protected from retaliation.

132. Complaints and Feedback

BNF’s Complaints & Feedback mechanism may also receive financial and corruption-related concerns. Personnel receiving such complaints should refer them to the appropriate responsible person or mechanism.

133. Safeguarding Link

Fraud and corruption may sometimes create safeguarding risks. For example:

demanding money from beneficiaries;
conditioning assistance on personal favors;
sexual exploitation in exchange for benefits;
abuse of authority;
manipulation of vulnerable persons.

Such concerns should also be managed under BNF’s Safeguarding Policy where applicable.

134. Conflict of Interest Link

The Anti-Fraud and Anti-Corruption Policy should be implemented together with BNF’s Conflict of Interest Policy. A disclosed conflict is not automatically misconduct. Failure to disclose or deliberate misuse of a conflict may create serious integrity risks.

135. Environmental and Social Safeguards Link

Fraud or corruption may undermine environmental and social safeguards. Personnel must not bypass environmental or social safeguards in exchange for personal or third-party benefits.

136. Record Retention

Relevant financial, procurement, project, and investigation records should be retained in accordance with BNF’s applicable procedures and legitimate retention requirements. Records relating to suspected fraud should not be destroyed while an appropriate review or investigation is ongoing.

137. Access to Records

Authorized auditors, investigators, management personnel, governance bodies, or other authorized persons may access relevant records where necessary and appropriate. Access should be controlled to protect confidentiality.

138. Confidentiality of Investigation Materials

Investigation records should be protected against:

unauthorized access;
unauthorized copying;
public disclosure;
retaliation;
manipulation; and
destruction.

139. Management of Recovered Funds and Assets

Recovered funds or assets should be properly recorded and managed. The use of recovered resources should be determined through appropriate organizational procedures.

140. Insurance and Financial Protection

Where relevant, BNF may maintain appropriate insurance or other financial protections against certain organizational risks. Insurance does not replace internal controls.

141. Third-Party Fraud

Where fraud is committed by a supplier, contractor, partner, or other third party connected with BNF, the organization may:

investigate;
suspend relevant transactions;
seek recovery;
require corrective action;
terminate contracts where appropriate;
notify relevant stakeholders; or
refer the matter to appropriate authorities.

142. Fraud by Employees

Employee involvement in fraud or corruption may result in organizational action in accordance with applicable employment procedures.

143. Fraud by Governance Members

Governance members are subject to the same fundamental standards of integrity. Concerns involving governance members should be directed through appropriate independent governance mechanisms.

144. Seniority Does Not Provide Immunity

No individual is exempt from this policy because of:

seniority;
organizational position;
professional status;
donor relationship;
political or institutional connection;
financial importance; or
personal relationship with BNF leadership.

145. Organizational Independence

BNF will seek to protect its organizational independence and ensure that financial or institutional relationships do not improperly determine organizational decisions.

146. Responsible Financial Stewardship

BNF recognizes that donor and organizational resources are entrusted to it for legitimate purposes.

Every person with financial responsibility should act as a steward of those resources.

147. Prohibited Conduct Summary

The following conduct is prohibited:

fraud;
theft;
embezzlement;
bribery;
kickbacks;
improper commissions;
extortion;
deliberate financial misrepresentation;
false expense claims;
fictitious transactions;
procurement manipulation;
false quotations;
collusion;
unauthorized use of assets;
diversion of project funds;
fraudulent beneficiary records;
research fabrication;
deliberate data falsification;
misuse of confidential information for personal gain;
undisclosed financial conflicts;
retaliation against reporters;
destruction of evidence; and
deliberate concealment of serious misconduct.

148. What Personnel Should Do When They Suspect Fraud

Personnel should:

prioritize immediate safety where relevant;
preserve relevant information;
avoid confronting a potentially dangerous person;
avoid destroying or altering evidence;
report the concern through an appropriate channel;
maintain confidentiality;
cooperate with legitimate review processes; and
avoid retaliation or unauthorized investigation.

Personnel are not expected to conduct their own formal investigation.

149. What Managers Should Do When They Receive a Report?

Managers receiving a serious concern should:

listen respectfully;
avoid dismissing the concern;
document relevant information;
maintain appropriate confidentiality;
assess immediate risks;
avoid retaliation;
refer the matter through the appropriate channel; and
avoid conducting an unauthorized investigation where this could compromise the process.

150. Ethical Decision-Making

When facing a potential integrity issue, personnel should ask:

Is this transaction authorized?
Is the information accurate?
Is there an undisclosed personal interest?
Is anyone receiving an improper benefit?
Could this harm BNF or its beneficiaries?
Are appropriate records being maintained?
Would the transaction withstand reasonable scrutiny?
Should I seek independent approval?
Should I report the concern?

151. Monitoring Policy Implementation

BNF may monitor implementation through:

financial reviews;
audits;
procurement reviews;
project monitoring;
management oversight;
risk assessments;
staff feedback;
complaints;
partner assessments; and
incident reviews.

152. Management Review of Fraud Risks

Senior management should periodically consider whether changes in:

projects;
funding;
staffing;
technology;
partnerships;
field locations;
procurement;
community activities; or
organizational structure

create new fraud or corruption risks.

153. Corrective Action Plans

Where weaknesses are identified, BNF may establish corrective action plans addressing:

control weaknesses;
staff training;
documentation;
supervision;
procurement;
authorization;
monitoring;
partner management; and
other relevant issues.

154. Policy Review

This policy should be periodically reviewed to ensure that it remains relevant to BNF’s:

organizational structure;
projects;
financial systems;
partnerships;
donor requirements;
field operations;
research activities; and
identified risks.

155. Public Accountability

BNF publishes this policy as part of its commitment to responsible stewardship, organizational transparency, ethical conduct, and accountability to communities, beneficiaries, donors, partners, government institutions, researchers, employees, and the public.

Publication of the policy does not replace detailed internal financial, procurement, investigation, or disciplinary procedures.

156. Contact and Reporting

Concerns regarding fraud, corruption, bribery, financial misconduct, procurement irregularities, or misuse of organizational resources may be reported through BNF’s designated channels.

Bangladesh Nature Foundation (BNF)

Sayman Road

Cox’s Bazar-4700, Bangladesh

Website: https://bdnature.org/

Anti-Fraud / Ethics Email: info@bdnature.org

Complaints & Feedback Email: info@bdnature.org

Where a concern involves the person normally responsible for receiving the complaint, the report should be directed to an alternative authorized governance channel.

Bangladesh Nature Foundation recognizes that trust is fundamental to conservation, environmental protection, community development, research, sustainable livelihoods, and organizational sustainability. BNF is committed to managing its funds, assets, information, partnerships, projects, and organizational authority responsibly. The organization will seek to prevent fraud and corruption through appropriate governance, financial controls, procurement safeguards, risk assessment, transparency, training, monitoring, reporting, and accountability. BNF will not knowingly tolerate deliberate fraud, bribery, corruption, theft, financial diversion, falsification, procurement manipulation, abuse of organizational authority, or other serious dishonest conduct. At the same time, BNF recognizes the importance of fairness. Allegations will be handled responsibly, good-faith reporters should be protected from retaliation, and persons accused of misconduct should be treated fairly during appropriate review processes. BNF encourages all staff, governance members, volunteers, researchers, consultants, partners, contractors, beneficiaries, community members, donors, and other stakeholders to raise legitimate concerns when they identify suspected fraud or corruption.

Protecting organizational resources is a shared responsibility. Preventing corruption is a shared responsibility. Maintaining public trust is a shared responsibility.

Through this policy, Bangladesh Nature Foundation reaffirms its commitment to:

Integrity. Transparency. Accountability. Responsible stewardship. Ethical conservation. Community protection. Scientific integrity. And responsible organizational management.

Related BNF Policies

This policy should be read together with:

Code of Conduct;
Safeguarding Policy;
Environmental & Social Safeguards Policy;
Conflict of Interest Policy;
Whistleblower Policy;
Complaints & Feedback Policy;
Gender Equality & Non-Discrimination Policy;
Research Ethics Policy;
Research Integrity Policy;
Data Protection & Management Policy;
Privacy Policy;
Copyright & Intellectual Property Policy;
Terms of Use; and
applicable financial, procurement, human-resource, project, and donor procedures.