Embassy of Botswana and Mission to the European Union
Anti-corruption policy statement 2017
1.1 The Embassy of Botswana in Belgium and Mission to the European Union recognises that corruption and fraud are a common challenge to any organisation. Accordingly, the Embassy has put in place some corruption prevention measures with a view to reduce incidences of corrupt practices. These measures include adherence to the following:
► Establishment of the Corruption Prevention Committee;
► Maintenance of the Gifts Register; and,
► Establishment of the Procurement Committee.
1.2 This Corruption Prevention Policy will therefore be critical in responding to all matters relating to the fight against corruption. The Embassy therefore undertakes to comply with this Policy in all its daily business operations.
2.1 This Policy applies to all staff members within the Embassy. It covers all activities undertaken by members of staff. It further encompasses key stakeholders of the Embassy who include the following:
(a) All suppliers, service providers and manufactures (and any other person(s) doing business, or wishing to do business with the Embassy from the effective date of this policy.
2.2 This Policy is intended to complement, and be implemented in conjunction with other Botswana Government policies and regulatory instruments including:
► General Orders
► Public Service Act
► Employment Act
► Finance and Audit Act
► Transport Orders
►Financial Instructions and Procedures
►Supplies Regulations and Procedures
►Public Procurement and Asset Disposal (PPAD) Act
►Trade Dispute Act
►Public Service Charter
3 // DEFINITION OF CORRUPTION
3.1 According to Part IV of the Botswana Corruption and Economic Crime Act of 1994; offences contained in Section 23 to 30 and 32 list acts which constitute corruption as follows: The offering, soliciting, acceptance and or promising of a valuable consideration which may influence the action of any person. For the purposes of the above-mentioned part, “valuable consideration” means:
- a) Any gift, benefit, loan, fee, reward or commission consisting of money or any valuable security or of other property or interest in property of any description;
- b) Any office, employment or contract;
- c) Any payment, release, discharge or liquidation of any loan, obligation or liability, whether in whole or in part;
- d) Any other service, or favour including protection from any penalty or disability incurred or apprehended or from any action or proceedings of a disciplinary, civil or criminal nature, whether or not already instituted;
- e) The exercise or forbearance from the exercise of any right or any power or duty; and
- f) Any offer, undertaking or promise whether conditional or unconditional, of any valuable consideration within the meaning of the provisions of any of the preceding paragraphs.
3.2 The clarification can be extended to outline that just as crime is an act or omission proscribed by punishable law, corruption is an act or omission for a reward or a valuable consideration (bribe). For corruption to take place there must be parties – corrupter and corruptee – whereas for economic crime to take place, valuable consideration (bribe) does not need to exchange hands. There has to be an intention of obtaining an advantage, avoiding an obligation or causing loss to another party. Examples of economic crime are cheating of public revenue through misappropriation; deception; forgery; extortion; conspiracy; embezzlement; false representation; concealment of material facts; collusion; etc. Money laundering and opportunistic theft also fall under economic crime.
4 // CORRUPTION RISK PRONE AREAS
4.1 The following areas and functions have been identified as risk prone areas:
► Recruitment process;
► Selection of staff for training;
► Theft /destruction of files and tampering with records;
► Adjudication of tenders;
► Contracts management;
► Procurement of goods and services;
► Supplies and stores management;
► Application for and retirement of imprests;
► Leakage of information on tenders;
► Bias reporting;
► Nepotism and favouritism;
► Collusion with suppliers; and,
► Misuse of vehicles and equipment, etc.
5 // STRUCTURES TO FIGHT CORRUPTION
5.1 The Embassy is committed to ensuring adherence to high standards of good governance in all its daily operations towards the execution of its mandate.
5.2 To this end, the following initiatives will be put in place in order to fight fraud and corrupt practices:
►Identify potential or actual corruption risk areas and promptly develop policies and procedures which will be communicated to all employees and monitored carefully;
►Undertake specific fraud and corruption risk assessments of high risk areas such as procurement, accounts payable and accounts receivable;
►Implement and monitor robust risk management and internal control systems that are easily accessible by internal and external auditors; and,
►Monitor the effectiveness of risk management in the implementation of key strategies and project based proposals.
6 // PREVENTIVE MEASURES
6.1 The Embassy undertakes to ensure that the internal control measures are enforced to address all incidences relating to the fight against corruption and fraudulent activities. To this end, the Embassy has in place some internal processes which are intended to attain the following key objectives:
► Appropriate internal control measures;
► Staff training and awareness;
► Cascading anti-corruption initiatives;
► Due diligence practices in the recruitment;
► Objective recognition and reward of
► Adherence to financial regulations and procurement procedures;
► Adherence to human resources regulations and procedures; and,
► Implementation of the recommendations of the Directorate on Corruption and Economic Crime.
7 // MANDATE AND OPERATIONS OF THE CORRUPTION PREVENTION COMMITTEE (CPC)
7.1 The CPC is responsible for keeping constant check on the Embassy’s operations and procedures to ensure that there are no opportunities for corruption. Other responsibilities of the Committee include:
► Ensuring that all corruption prevention initiatives are integrated in the Embassy’s Policy document;
► Sensitising staff on issues relating to corruption in the Embassy;
► Undertaking risk assessment within the Embassy and to come up with anti-corruption prevention measures;
► Receiving and reviewing reports on corruption prevention initiatives and recommending appropriate action;
► Ensuring that all decisions and guidelines on corruption prevention are communicated effectively to the employees of the Embassy and interested parties;
►Receiving complaints and information on alleged corrupt activities, and thereafter evaluating, analysing and recommending appropriate action where possible;
►Monitoring the impact of corruption prevention initiatives and other recommended actions; and,
►Coordinating corruption prevention strategies in the Embassy.
8 // RESPONSIBILITIES
Senior Management will be responsible for:
► Ensuring that all staff are aware of overall anti-corruption and fraud policy objectives and carry out their duties and responsibilities for prevention;
► Creating an environment that discourages fraud and corruption in the work place;
► Ensuring that new Employees are cultured to resist fraud and corrupt practices and solely operate in line with the Embassy’s Code of Conduct;
► Identifying potential fraud and corruption risk areas and mitigating against them;
► Leading by example to promote ethical behaviour;
► Ensuring that internal controls are complied with at all times; and,
► Ensuring that appropriate anticorruption reporting, monitoring and control systems are in place.
8.2 Employees will be responsible for:
► Performing their functions and duties with care, diligence, honesty and integrity;
► Conducting themselves in a professional manner at all times;
► Adhering to these guidelines and other procedures that have been established to prevent fraud or corruption;
► Taking care of Botswana Government property which includes avoiding the waste or misuse of resources;
► Enhancing the reputation of the Embassy;
► Remaining scrupulous in their use of the Embassy’s information, assets, funds, property, goods or services;
► Reporting any occurrence of fraud and/or corruption within the Embassy to a Responsible Officer;
► Acting with honesty at all times;
► Ensuring a proper balance of level of responsibility, discretionary authority and accountability;
► Ensuring proper security and handling of Government resources and funds whether they are payments
or receipts from contractors and others;
► Reporting timeously to a line manager or through a confidential whistle-blowing process or service any evidence or suspicion of fraud and corruption or failure to carry out procedures properly; and,
► Reporting any weaknesses they identify when carrying out their duties thus playing their part in compliance.
9 // EDUCATING FOR AWARENESS
9.1 The Embassy recognises that the success and credibility of this Policy will largely depend upon how effectively it is communicated throughout the organisation and beyond. The Embassy will increase community awareness by:
► promoting the Embassy’s initiatives and policies regarding the control and
prevention of fraud and corruption via its website and within the Chancery.
9.2 The Embassy’s standards regarding ethical behavior will be conveyed to customers, stakeholders and the community through the manner in which its employees conduct business with them.
10 // EMPLOYEE AWARENESS
10.1 Staff awareness will be developed through:
► Staff familiarising themselves with the relevant conduct standards including the Code of Conduct;
► Involvement of supervisors and managers in risk assessment activities;
► The use of staff meetings and training sessions to identify the corruption risks inherent to an activity or
workplace, and the controls in place to address them including questions on ethics issues and ethical practice in staff selection interviews; and,
► Providing corruption awareness publications including resources made available on the Embassy’s website.
11 // CONFIDENTIALITY
11.1 Under this Policy, persons receiving allegations and conducting investigations have a responsibility to ensure that information which might identify the person making the allegations is strictly kept confidential.
12 // REVIEW OF POLICY
12.1 The Policy Statement will be subject to review at least once every five years with midterm reviews.
13 // CONCLUSION
13.1 Successful implementation and sustainability of the Policy will be achieved through amongst others, employees’ commitment, zero tolerance for fraud and corruption, stakeholder collaboration and strong commitment by the management to lead in efforts to prevent corruption.