1. Preamble

Tupendane Foundation and Initiatives (TUFOI) is committed to empowering communities through education, social services, health, environmental protection and community development.

As an organization entrusted with funds, assets and resources from members, donors, partners and other supporters, TUFOI recognizes the importance of integrity, transparency, responsible financial management and accountability.

This Anti-Fraud, Anti-Corruption & Financial Accountability Policy establishes TUFOI's commitment to preventing, identifying and addressing fraud, corruption, misuse of organizational resources and other forms of financial misconduct.

The policy is intended to protect TUFOI's resources, maintain the confidence of members and supporters, and ensure that organizational funds are used for the purposes for which they are entrusted.

2. Purpose

The purpose of this policy is to:

  • Promote honesty, integrity and accountability throughout TUFOI.
  • Protect organizational funds, property and other resources from misuse.
  • Prevent fraud, corruption, bribery and other forms of financial misconduct.
  • Establish clear financial accountability responsibilities.
  • Promote proper record keeping and financial reporting.
  • Provide a framework for addressing suspected or actual financial misconduct.
  • Support responsible management of funds received from donors, members, partners and other sources.

3. Scope

This policy applies to persons acting on behalf of or representing TUFOI, including:

  • Board members and office bearers.
  • Employees and volunteers.
  • Members of the organization.
  • Consultants and freelancers engaged by TUFOI.
  • Contractors and service providers.
  • Partner organizations and other representatives acting on behalf of TUFOI.

All persons covered by this policy are expected to conduct themselves honestly and responsibly and to protect TUFOI's interests and resources.

4. Sources of Funds

The TUFOI Constitution identifies the following sources of organizational funds:

  • Entry and annual membership fees.
  • Fundraising.
  • Legal gifts from friends.
  • Grants and donations.
  • Income-generating activities.
  • Members' contributions.
  • Gifts.

Regardless of the source, all funds received by TUFOI shall be managed responsibly and applied toward the objectives of the organization.

5. Use of Organizational Funds

The TUFOI Constitution provides that funds obtained by the organization shall be applied solely toward the promotion of its objectives.

Accordingly:

  • Organizational funds shall only be used for legitimate TUFOI purposes.
  • Organizational resources shall not be used for personal benefit or unauthorized purposes.
  • Expenditure shall be properly authorized and recorded.
  • Organizational property and assets shall be protected from loss, theft, unauthorized use or disposal.
  • Financial resources shall be managed in accordance with TUFOI's Constitution and applicable requirements.

6. Definition of Fraud and Corruption

For the purposes of this policy, fraud and corruption include dishonest, deceptive or unauthorized conduct involving organizational funds, assets, responsibilities or decision-making.

Examples may include:

  • Bribery or attempted bribery.
  • Embezzlement or theft.
  • Misappropriation of organizational funds or property.
  • Unauthorized use of TUFOI resources.
  • Deliberate falsification or alteration of financial records.
  • Submission of false financial information or claims.
  • Concealment of financial misconduct.
  • Abuse of entrusted authority or organizational resources.
  • Nepotism or improper preferential treatment.
  • Other dishonest conduct intended to obtain an improper personal or organizational advantage.

This list is not intended to limit the types of conduct that may constitute fraud, corruption or financial misconduct.

7. Standards of Conduct

All persons covered by this policy are expected to:

7.1 Comply with applicable requirements

Respect the laws, regulations, TUFOI Constitution and organizational rules applicable to their responsibilities.

7.2 Reject fraud and corruption

TUFOI does not accept fraud, corruption, bribery or deliberate misuse of organizational resources.

7.3 Protect organizational resources

TUFOI funds, property and other resources must be used only for legitimate organizational purposes.

7.4 Maintain transparency

Individuals acting on behalf of TUFOI should separate personal interests from organizational responsibilities and disclose actual or potential conflicts of interest where appropriate.

7.5 Gifts and benefits

Gifts, hospitality or other benefits must not be used to improperly influence organizational decisions or obtain an improper advantage.

Cash gifts connected to organizational decisions or transactions are prohibited.

Modest and customary hospitality may be accepted where it is appropriate, lawful and does not create an improper obligation.

7.6 Public officials and political influence

TUFOI shall not provide improper payments, gifts or benefits to public officials, government employees, political parties or other persons for the purpose of obtaining an improper advantage.

7.7 Fundraising integrity

TUFOI fundraising activities should be conducted honestly and transparently. Individuals acting on behalf of TUFOI must not make false promises or deliberately misrepresent the organization's activities or use of funds in order to obtain donations.

7.8 Reporting concerns

Suspected fraud, corruption or serious financial misconduct should be brought to the attention of the appropriate TUFOI leadership, including the Board where appropriate.

7.9 Cooperation

Individuals are expected to cooperate honestly with legitimate organizational reviews or investigations concerning suspected financial misconduct.

8. Financial Records and Reporting

The Treasurer has specific financial responsibilities under the TUFOI Constitution.

The Treasurer shall:

  • Receive and keep organizational funds.
  • Prepare the annual budget and financial estimates for presentation to the General Meeting.
  • Maintain financial records, asset records, accounts and books of account.
  • Prepare financial statements of income and expenditure.
  • Submit financial documents together with the audited report to the General Meeting.

The TUFOI Board of Directors is responsible for setting overall operational and financial guidelines and appointing auditor(s).

9. Bank Account Controls

TUFOI shall maintain a bank account in the name of the organization as provided by its Constitution.

The Constitution provides that the office bearers are signatories to the organization's bank account. The office bearers are the Chairperson, Secretary and Treasurer.

For any transaction to be effected, two of the three authorized signatories must sign.

This requirement provides an important control over organizational funds by ensuring that financial transactions do not depend on the authorization of a single signatory.

10. Internal Financial Accountability

TUFOI's financial accountability is supported through its governance structure.

Board of Directors

The Board of Directors is responsible for:

  • Setting overall operational and financial guidelines.
  • Protecting and advancing the image of the organization.
  • Participating in the development of organizational strategic plans.
  • Appointing auditors.
  • Establishing committees where necessary.
  • Considering projects and feasibility studies before their submission for General Meeting approval.

Treasurer

The Treasurer is responsible for the financial record-keeping and reporting functions established by the Constitution.

General Meeting

The General Meeting is the supreme organ of TUFOI.

It is responsible for discussing and approving annual budgets, plans and physical and financial implementation reports.

11. Reporting and Handling of Concerns

TUFOI encourages members, employees, volunteers, partners and other stakeholders to raise genuine concerns regarding suspected fraud, corruption, misuse of funds or other financial misconduct.

Concerns should be communicated to appropriate TUFOI leadership.

Where a matter constitutes an internal organizational conflict, the Constitution provides that the Board of Directors is responsible for settling the dispute. If the Board is unable to resolve the matter, it may be referred to the General Meeting.

TUFOI will seek to consider genuine concerns fairly and responsibly, consistent with its Constitution and applicable requirements.

12. Protection of Organizational Resources

All TUFOI members, staff, volunteers, Board members, contractors and representatives have a responsibility to protect organizational resources.

This includes:

  • Money and financial assets.
  • Buildings and equipment.
  • Documents and records.
  • Organizational information.
  • Project resources.
  • Donated goods and materials.
  • Other property belonging to or entrusted to TUFOI.

Unauthorized use, theft, deliberate damage, concealment or misuse of organizational resources is prohibited.

13. Consequences of Violations

A person who violates this policy may be subject to appropriate action in accordance with the TUFOI Constitution, applicable organizational procedures and the law.

Depending on the nature and seriousness of the conduct, consequences may include:

  • Disciplinary action.
  • Removal from organizational responsibilities where applicable.
  • Termination of an employment, consultancy or contractual relationship where applicable.
  • Recovery of improperly used or lost organizational resources.
  • Referral of suspected criminal conduct to the relevant authorities where appropriate.
  • Membership disciplinary action in accordance with the Constitution.

The TUFOI Constitution provides for expulsion of members for misbehavior or failure to adhere to organizational resolutions and the Constitution.

14. Gifts and Benefits

TUFOI recognizes that gifts and hospitality can create actual or perceived conflicts of interest.

Accordingly:

  • Cash gifts connected to TUFOI decisions, procurement, fundraising or other organizational activities are prohibited.
  • Gifts must not be accepted or offered for the purpose of influencing a decision or obtaining an improper advantage.
  • Modest and customary hospitality may be accepted when appropriate and lawful.
  • Work-related travel, invitations or events involving external organizations should be considered carefully and, where appropriate, approved through the relevant organizational authority.
  • Promotional items of modest value may be accepted where they are clearly promotional and do not create an improper obligation.

Gift Value Guidelines

The following internal guidelines may be used by TUFOI when formally adopted and approved:

  • Cash gifts: Prohibited.
  • Gifts up to TZS 100,000: May be accepted where appropriate and not intended to influence a decision.
  • Gifts above TZS 100,000 and up to TZS 300,000: Should require appropriate organizational approval.
  • Gifts above TZS 300,000: Should not be accepted without formal organizational consideration and approval.
  • Hospitality: Should be modest, appropriate and related to legitimate organizational activities.
  • Promotional items: May be accepted where they are clearly promotional and do not create an obligation.

Any gift or benefit that appears intended to influence a decision, secure preferential treatment or obtain an improper advantage should be declined or reported to the appropriate TUFOI leadership.

15. Emergency Payments

Where an individual is compelled to make a payment because of an immediate and credible threat to life or personal safety, the matter should be reported to TUFOI leadership as soon as reasonably possible.

Such circumstances should not be used as a justification for ordinary unauthorized payments.

16. Financial Year

The financial year of TUFOI runs from 1 January to 31 December of each calendar year.

Financial reporting and accountability should therefore be organized in accordance with this financial year and the reporting requirements established by the organization.

17. Review and Amendment

This policy should be reviewed periodically to ensure that it remains appropriate for TUFOI's activities and governance arrangements.

Any changes that affect the TUFOI Constitution must follow the constitutional amendment process.

The Constitution provides that amendments may be made by the General Meeting by majority vote of eligible voters held for that purpose.

18. Effective Date

Effective Date: To be approved by TUFOI

Approved By: Tupendane Foundation and Initiatives (TUFOI)

Review Date: To be determined by TUFOI

This policy shall remain in effect until it is amended, replaced or withdrawn through the appropriate organizational process.

Policy Statement

Tupendane Foundation and Initiatives (TUFOI) is committed to using the resources entrusted to it responsibly and solely in support of its organizational objectives.

Through responsible financial management, proper record keeping, Board oversight, General Meeting accountability and appropriate internal controls, TUFOI seeks to maintain the trust of its members, beneficiaries, donors, partners and the communities it serves.