Anti-Fraud, Bribery and Corruption Policy

Al-Waris Foundation has zero tolerance for fraud, bribery, corruption, theft, deliberate financial dishonesty or intentional misuse of charitable resources.

Charitable funds and assets must be used only for legitimate purposes consistent with:

Al-Waris Foundation will maintain proportionate arrangements to:

This policy establishes Al-Waris Foundation's approach to:

This policy applies to:

It applies to activity undertaken:

The Board of Trustees retains ultimate responsibility for protecting the charity's assets.

Trustees should ensure that proportionate controls exist to reduce the risk of:

Operational responsibilities may be delegated.

Delegation does not remove trustee oversight responsibility.

Fraud generally involves deliberate dishonesty intended to produce a gain or cause a loss.

Potential charity fraud may include:

This list is not exhaustive.

Theft or unauthorised appropriation of:

must be treated seriously.

The value involved is relevant but is not the only factor determining seriousness.

Al-Waris Foundation prohibits bribery.

No person acting for the charity may offer, promise, give, request or accept an improper advantage intended to influence conduct improperly.

Bribery may involve:

Corruption includes abuse of entrusted authority for improper private benefit.

Examples may include:

Al-Waris Foundation will conduct its activities consistently with applicable UK anti-bribery law.

The charity must not:

Appropriate preventative procedures should reflect the charity's actual bribery risks.

This policy applies to Al-Waris Foundation's overseas activities.

Conduct does not become acceptable merely because:

Higher-risk environments may require enhanced controls.

Unofficial payments intended to improperly speed up or secure routine actions must not normally be made.

A payment does not become acceptable merely because it is:

Legitimate official charges should, where reasonably practicable, be supported by:

Where a person faces an immediate and genuine threat to safety and a payment or transfer of property is demanded, personal safety takes priority.

The incident should be reported internally as soon as reasonably practicable afterward.

The charity should:

Such circumstances are distinct from paying for commercial convenience.

Gifts and hospitality must not be used to:

Modest and legitimate hospitality may be acceptable where it is:

A trustee or representative should decline a gift where accepting it could reasonably create:

Material gifts offered because of a person's Al-Waris Foundation role should be disclosed.

Ordinary charitable assistance provided to beneficiaries is not considered a gift for the purposes of anti-bribery controls where it is provided according to legitimate charitable criteria.

Beneficiary selection must not depend on:

Conflicts can increase fraud and corruption risk.

Anyone involved in a financial or procurement decision must disclose relevant interests.

Examples include relationships with:

See the Conflict of Interest Policy.

Transactions involving trustees or connected persons require enhanced scrutiny.

Any such arrangement must:

A conflicted trustee must not improperly influence the decision.

Procurement fraud may include:

Material purchasing should follow the Procurement and Purchasing Policy.

Written quotations should be obtained where proportionate.

The charity should take reasonable steps to establish that quotations are genuine.

Warning signs may include:

Before appointing a material contractor, checks may include:

The level of due diligence should reflect risk.

Where practical, new contractors undertaking repeatable project work should initially receive a limited pilot rather than a substantial batch of projects.

The pilot may be assessed for:

Successful completion does not eliminate future monitoring.

Payments should normally be made to an account legitimately associated with the contractor or supplier.

Requests to pay:

should receive additional verification.

Bank-detail changes should be independently verified where reasonably practicable.

Invoices must not knowingly be:

Material discrepancies should be investigated.

Project fraud may include:

Project evidence should be proportionate to risk and expenditure.

Water projects should normally maintain an evidence trail including:

Where payment depends on depth or specification, the charity should obtain reasonable evidence of the actual completed work.

Where appropriate, completed physical projects should display an Al-Waris Foundation project number or branded plaque.

This may assist:

Project identification should not create unnecessary security or safeguarding risk.

Risks in food and essential-aid distributions may include:

Controls may include:

Controls must remain proportionate and respect beneficiary dignity.

Evidence of need should be proportionate.

The charity should not create unnecessarily burdensome systems merely to eliminate every possibility of beneficiary fraud.

Where deliberate material deception is identified, assistance may be:

Safeguarding and vulnerability should be considered before recovery action.

No person may knowingly fabricate beneficiary identities, numbers or circumstances in order to:

No person may knowingly create or submit false:

AI-generated content must not be knowingly presented as genuine documentary evidence of completed charitable activity.

AI-generated or materially manipulated content must not be represented as:

when it is not.

Illustrative AI content may be used where it is not misleadingly presented as evidence of real charitable work.

Donation-related fraud may include:

Online donation systems should maintain appropriate audit trails.

Restricted donations must not knowingly be diverted to unrelated purposes.

The charity should maintain records allowing restricted income and expenditure to be appropriately identified.

See the Financial Controls and Reserves Policy.

Cash presents increased fraud risk.

Controls may include:

Unexplained differences should be investigated.

Collectors must not:

Appropriate supervision should be maintained.

Digital fraud may involve:

Suspicious activity should be escalated promptly.

See the Information Security and Cybersecurity Policy.

Unexpected payment instructions received by email should be treated cautiously.

Particular care should be taken with:

Independent verification should be used where reasonably practicable.

Access to:

should follow least-privilege principles.

Access should be removed when no longer required.

Multi-factor authentication should be used where available.

No person may knowingly:

Accounting corrections must remain traceable.

Expense claims must reflect genuine costs incurred for legitimate charity purposes.

Examples of prohibited conduct include:

See the Expenses Policy.

Grant applicants or recipients must not knowingly provide false information to obtain or retain funding.

Where material deception is discovered, Al-Waris Foundation may:

See the Grant Making Policy.

Overseas partners must be subject to proportionate due diligence and monitoring.

Warning signs may include:

Concerns should be investigated rather than automatically treated as proof of wrongdoing.

Fraud controls should operate alongside sanctions and terrorist-financing controls.

The charity must not knowingly allow charitable resources to be diverted to prohibited persons or organisations.

See the Sanctions and Terrorist Financing Policy.

Anyone who suspects fraud, bribery or corruption connected with Al-Waris Foundation should report it promptly.

Reports may be made to:

A person should not delay reporting merely because they do not have complete proof.

Where a concern involves the Chair, it should be reported directly to another unconflicted trustee.

The Chair must not control an investigation into allegations concerning their own conduct.

Where a trustee is implicated:

Where effective internal management is not possible, external regulatory reporting may be necessary.

People raising genuine concerns should not be subjected to inappropriate retaliation.

See the Whistleblowing Policy.

Knowingly false allegations may be dealt with appropriately, but an allegation is not malicious merely because it is unproven.

When suspected fraud, bribery or corruption is identified, the charity should consider immediate steps to:

Relevant evidence should be protected from:

Evidence may include:

Investigations should be:

An allegation should not automatically be treated as established fact.

Independent professional investigation or advice should be considered where:

Where necessary to protect charitable assets or evidence, the charity may temporarily restrict a person's access to:

This is a protective measure and does not by itself establish wrongdoing.

Where charitable assets have been improperly obtained or diverted, the trustees should consider reasonable recovery action.

Factors may include:

Where fraud involving a contractor is established or sufficiently serious concerns remain, Al-Waris Foundation may:

Where fraud involving a partner organisation is identified, the charity may:

Where relevant, suspected financial fraud should be reported promptly to:

Prompt reporting may improve the possibility of preventing or recovering loss.

Suspected criminal conduct may require reporting through appropriate official channels.

The charity should use the current official reporting route applicable to the circumstances.

An internal investigation should not obstruct or compromise a law-enforcement investigation.

Significant fraud, financial loss, trustee misconduct or misuse of charitable assets may constitute a serious incident.

The Board must assess whether the matter should be reported to the Charity Commission.

See the Serious Incident Reporting Policy.

Depending on the circumstances, the charity may need to consider reporting to:

One regulatory report does not necessarily satisfy another reporting obligation.

Where the charity has relevant insurance, the insurer should be notified where required by the policy.

The charity should avoid taking steps that unnecessarily prejudice legitimate insurance recovery.

Fraud investigations must be handled confidentially.

Information should be shared only where reasonably necessary for:

Personal data processed during investigations must be handled in accordance with:

An allegation does not justify unrestricted disclosure of personal information.

Appropriate records should be maintained of:

Records should be retained according to the Records Retention and Disposal Policy.

The charity may maintain a restricted fraud and financial-irregularity register.

Entries may include:

Access should be restricted.

Following a material incident, Al-Waris Foundation should assess:

Corrective actions should be monitored where material.

No person acting for Al-Waris Foundation may deliberately conceal serious fraud, bribery or corruption merely to:

Reputation should be protected through appropriate governance and corrective action.

Relevant trustees, volunteers and authorised personnel should receive proportionate guidance concerning:

The Board should receive proportionate information about significant:

Sensitive personal information should not be circulated more widely than necessary.

Breaches may result in:

Action should be proportionate to the circumstances.

This policy should be read alongside:

This policy will be reviewed:

Version: 2.0 Status: Approved Approved by: Board of Trustees Approval date: 25/08/2026 Next scheduled review: 24/08/2027