Corruption is found in all countries, but the extent and scope varies. Fragile and conflict affected states are in particular exposed to corruption. Transparency International's corruption index ranks countries based on how their public sector is perceived. Not surprisingly, many countries where NRC works are ranked as the most corrupt countries in the world. Hence understanding and fighting corruption in the different contexts in the countries we work, require extra attention and efforts.
NRC defines corruption as "the abuse of power for illegitimate individual or group benefits". This involves financial and non-financial benefits. We have zero tolerance against corruption, and NRC employees are not allowed to provide for, request or receive anything that can be defined as corruption.
To help and support staff and management in avoiding and handling corruption cases, we have a detailed Code of Conduct, an Anti-corruption handbook and strict Human Resource, Logistics and Financial procedures. This is coupled with whistle blowing procedures, Monitoring & Evaluation and Risk Management systems put in place. NRC's Anti-corruption handbook describes how our anti-corruption policy should be implemented and helps NRC's managers and staff to better understand the overall corruption threats and how to apply appropriate control measures throughout the organisation. Our procedures and control mechanisms are constantly strengthened and adjusted to further improve our global and country specific prevention measures.
Support and programme functions in humanitarian operations and acute emergencies are in particular exposed to corruption. However, our experience is that regular monitoring, including unannounced spot checks, and segregation of duties generally serve as effective prevention measures.
In 2017, a new round of awareness raising and context specific anti-corruption trainings were done in the programme countries. We also continued to arrange investigation trainings of key staff in cooperation with external investigation experts. Assessing and investigating alleged corruption and proving evidence is important, but can be resource demanding, difficult, and even dangerous. In criminal cases we alert the police and take legal action, if appropriate. In some countries however, the police and prosecutors can be part of the crime or otherwise corrupt, thus in certain cases/countries extra care and discretion must be used before taking legal action.
During 2017, a total of 55 cases of alleged corruption were investigated.
All cases were detected as a result of NRC's internal control measures or through whistle blowing. In each of the cases where irregularities or misconduct were found we have learned from the incidents. Proper prevention measures were applied accordingly and appropriate level of disciplinary actions taken in each case according to NRC policy and local law. Affected donors have been informed and where money has been lost the loss has been covered by NRC and/or wherever possible the loss has been recovered from the staff in question.
One of the cases was investigated by external experts, the rest by internal investigation teams, following NRC's investigation procedures. 31 cases were found to be either groundless, not substantiated or related to negligence and bad performance, rather than of a Code of Conduct nature. Six cases are (pr early June 2018) pending final conclusion.
In the 18 cases presented below, the investigations concluded that misconduct had taken place:
Case 1) Fraud/fake vouchers and inflated prices
End 2016, through internal control the management became suspicious of possible fraud related to maintenance and running costs of the Kabul office.
The investigation concluded that two staff members had been faking vouchers and inflating prices amounting to a total financial loss of USD 38,121
Fraud/ fake receipts
Mid-June 2017 a staff member submitted a settlement of advance taken to clear WASH items from the Djibouti Airport. Three receipts were submitted, one original with a serial number and two other receipts with suspected erased serial numbers. Verification of the financial documents were done and fraud confirmed. The financial loss is USD 1,274.
Case 1) Inflated fees and fake finger prints
Early February, the management in an area office detected possible fraud within the education programme related to payments for enrolling children in schools. The investigation found that several beneficiary families were stating that they had not received this money and there were indicators that up to 60% of the fingerprint receipts had been forged. This implies fraud amounting to USD 1,524 in total.
Case 2) Bribery/kickbacks within recruitment
End June, two local Security Service Officers reported that some of their relatives had been selected as service drivers for NRC and had paid bribes to NRC staff. The investigation concludes there was enough evidence against the subject of the complaint of taking bribes from the NRC drivers and acting as middle-man to pay these bribes higher up the management scale. It further showed that the manager in charge failed to manage and follow proper tendering process in the latest hiring of drivers and for receiving bribery.
Case 3 Leaking recruitment tests
Early July, a Programme Manager received a whistle blow about an information leak in connection with a recruitment case. The investigation proved that confidential interview questions had been leaked by one staff member to a potential candidate. The misconduct was reported and detected before the recruitment was finalised.
Case 4) Conflict of interest
Early September, a whistle blow was alleging a conflict of interest between a staff member and a supplier. Evidence was found that the subject of the complaint had signed a framework agreement with his wife's step-brother and also signed a renewal to that agreement without declaring or completing a conflict of interest statement
Kenya (Country office)
Case 1) Illegal water connections
In March, NRC received complaints that refugees were experiencing water shortage in the camp. When checking, 42 illegal water connections were detected and allegations of NRC staff being involved and taking fees resulted in a proper investigation. The investigation found a total of 52 illegal connections ranging from individual households to learning institutions and mosques. It also confirmed that in long term and large scale refugee camps illegal water connections are almost unavoidable. The water in the camp is supplied for free. Households had purchased pipeline materials and paying labour for the plumbers to tap into a public (free) water resource, into their private households. It was not possible for the investigation team to determine precisely how many of the connections that were done after NRC took over the water network management in 2013. However, it was reasonably concluded that most of the illegal connections happened at night and that NRC's WASH programme materials were not used for the illegal connections. The investigation could not prove that NRC staff or incentive refugee workers were receiving payments for the illegal water connections.
Case 2) Alleged fuel theft
Mid July, NRC received a complaint alleging that a group of NRC staff was selling diesel meant for 6 borehole generators in Hagadera camp. The investigation did not manage to prove this, but revealed a clear case of negligence from the staff's responsibility and it was reasonably inferred from the various witness statements that fuel use irregularity had occurred at the NRC operated boreholes.
Case 3) Procurement collusion
Mid July, six complaints purportedly coming from six different suppliers on the same day were accusing two NRC staff of working with a selected group of suppliers, awarding contracts to companies with whom they have affiliations and that some of the suppliers are presenting several businesses, but being owned by one individual.
The investigation concluded that there had been intentional bypassing of NRC's procurement procedures and collusion on a number of fronts between NRC staff and suppliers. The pre-approved supplier list for 2017 had been tampered with. It was not possible to quantify any monetary losses because goods, works and services were indeed rendered and the documents seemingly in order. The main malpractice being that some vendors were providing their own quotations to meet the threshold required for an order to be processed.
Case 4) Fuel theft
Early November, a NRC staff caught a Security Service Guard carrying a 5 litre container full of diesel. This led to checks of the NRC fuel bunker and it was revealed that the actual available diesel was 2,800 litres against 3,514litres in the record; making a deficit of 714 litres. The case was reported to the police and an investigation was handled by the police and the security company. The police did not find sufficient evidence against the security guard. NRC tried to assess if any NRC staff could have been involved, but it was not possible to obtain sufficient evidence to prove it or to pin it on a particular person(s). The value of the missing 714 litres of fuel was USD 760.
Kenya (Regional Office)
In July, NRC 's Regional Office conducted a physical count of all assets/ inventory and during this process it was discovered that some radio equipment and accessories were missing from the store room. The missing radio equipment had been donated to the Regional Office from the exiting Uganda Country Office back in 2014. The investigation concludes that the items were stolen, but it was not possible to obtain sufficient evidence to pin it on a particular person(s). There is no financial loss as the equipment was fully depreciated.
Mid-December, NRC received a complaint that some beneficiaries of NRC's cash distribution had received less amounts than initially announced during the project launch. The investigation concluded that NRC's cash distribution routines had not been properly followed. 280 beneficiaries claimed they received XOF 28,000 instead of the full XOF 30,000 while 31 beneficiaries had received XOF 15,000 instead of 30,000, amounting to a total financial loss of USD 1,839. The cash transfer was made through a supplier and the supplier has committed to reimburse the loss as the contract provisions had not been followed.
Falsification of travel claims
Early March, two staff members were found guilty of falsification travel claims from a field travel. The loss was recovered by the staff's final dues.
Case 1) Stolen antennas
End January, during an auditor's asset control it was revealed that some antennas from 2005, 2008 and 2011 were missing. An investigation was launched and proved that the antennas were stolen, but it was not possible to prove who did it. The theft was reported to the police. Due to the age of the items there is no actual financial loss.
Case 2) aid diversion
Early June, NRC received a complaint from a village resident that the community committee had requested all clients to contribute USD 25 from the NRC assistance per house hold. The purpose of this payment was reportedly USD 20 as incentive to the community committee members while USD 5 was to cover transportation costs of a selected community member who would go to the town where there is mobile connection and cash the mobile money on behalf of the beneficiaries. The investigation proved that the allegations were correct. Ninety beneficiaries from that specific village (out of 100) confirmed that they had paid USD 25 to the village committee. The case was reported to all the relevant Government authorities for corrective actions. There was no financial loss as NRC managed to reclaim the money from the village committee and paid back to all affected beneficiaries.
Case 1) Fraud/manipulation of documents/figures
End May, during routine control it was detected that supporting documents for one voucher were missing. When checking this it was detected that the payments done to translators and local leaders who participated at a youth skills training in three locations had been manipulated. NRC therefore paid USD 117 extra. The person in charge of these payments admitted that he had manipulated the figures. The financial loss was covered by the persons final dues.
Case 2) theft of money
End July, when reviewing the fuel records for one of the vehicles, the mileage covered was less by about 50% compared to previous mileage for the same amount of fuel. The Driver was contacted to provide an explanation and admitted he had a personal problem and therefore had used part of the fuel money for personal gain. There was no financial loss as the amount in question was recovered from the staff's final dues.
In October, NRC received a complaint through its feedback hotline of improper use of shelter materials in one village.
The investigation proved that one NRC staff had used his/her position to target shelter assistance to his/her own relatives (2 households). The investigation further confirmed that these two households had not sustained conflict-related damages and therefore did not meet the selection criteria. The financial loss due to the improper targeting of this shelter assistance is USD 1,048.