Anti-Fraud and Anti-Corruption Policy

1. Purpose and zero tolerance

Axiom Santé works with public and charitable funds intended to improve people's health. Every dollar diverted is a health service lost. The firm therefore applies a zero-tolerance policy: no form of fraud, corruption, collusion, coercion or obstruction is accepted, whatever the amount, the beneficiary or the justification given (local custom, urgency, pressure from a third party).

This policy draws on the United Nations Convention against Corruption (UNCAC, 2003), to which the Democratic Republic of the Congo acceded on 23 September 2010; the World Bank Guidelines on Preventing and Combating Fraud and Corruption (the "Anti-Corruption Guidelines"); the Uniform Framework for Preventing and Combating Fraud and Corruption adopted by the multilateral development banks in 2006; and the UN Supplier Code of Conduct. It complements our ethics policy.

2. Scope

The policy applies to everyone acting for or on behalf of Axiom Santé: Management, permanent staff, associate experts, consultants, enumerators, supervisors and drivers, as well as subcontractors and suppliers in the services they deliver for the firm. It covers every stage of an assignment: proposal preparation, negotiation, delivery, field payments, reporting and close-out. Its obligations are written into contracts and terms of engagement; a breach constitutes serious misconduct.

3. Sanctionable practices

Axiom Santé uses the harmonised definitions of the multilateral development banks, which UN procurement rules also adopt as "proscribed practices":

Practice	Definition
Corrupt	Offering, giving, receiving or soliciting, directly or indirectly, anything of value to influence improperly the actions of another party.
Fraudulent	Any act or omission, including a misrepresentation, that knowingly or recklessly misleads, or attempts to mislead, a party to obtain a financial or other benefit or to avoid an obligation.
Collusive	An arrangement between two or more parties designed to achieve an improper purpose, including to influence improperly the actions of another party.
Coercive	Impairing or harming, or threatening to impair or harm, directly or indirectly, any party or its property to influence improperly the actions of a party.
Obstructive	Destroying, falsifying, altering or concealing evidence, making false statements to investigators, threatening or intimidating any person to prevent them from giving evidence, or impeding a funder's inspection and audit rights.

Concrete examples in our work: invoicing survey days that did not take place, inflating the number of workshop participants, inventing or copying questionnaires, submitting false fuel receipts, paying a commission to obtain a data collection permit, or agreeing prices with another bidder.

4. Conflicts of interest, money laundering and sanctions

Conflicts of interest. Anyone involved in selecting an expert, subcontractor or supplier declares in writing any family, financial or professional tie with a candidate and withdraws from the decision. Axiom Santé does not bid in a tender whose terms of reference it drafted or about which it has received information not available to other bidders, and informs the client of any actual or apparent conflict of interest as soon as it becomes aware of it.

Money laundering and terrorist financing. The firm accepts no payment whose origin cannot be identified and neither receives nor makes payments on behalf of a third party that is not party to the contract. Before contracting, every subcontractor, supplier and associate expert is screened against:

• the United Nations Security Council Consolidated List;
• the World Bank Listing of Ineligible Firms and Individuals;
• any other exclusion list required by the contract (for example those of the European Union or the relevant funder).

Screening is dated, filed in the procurement record and repeated for each new contract. A positive match ends the relationship immediately and the client is informed.

Sanctions compliance. Axiom Santé makes no funds or services available to any person or entity subject to applicable sanctions and complies with the sanctions clauses of each contract.

5. Gifts, hospitality and per diems

• Only gifts and hospitality of modest value, given occasionally and unrelated to any pending decision, may be accepted or offered, up to USD 25 per occasion.
• Any gift or invitation worth more than USD 25 is declined or, where declining would cause offence, handed to Management. Every gift above this threshold, whether accepted or declined, is entered in the gifts and hospitality register kept by Management.
• No gift or hospitality of any value is offered to a public official: Congolese law sets no tolerance threshold for corruption.
• No gift of any value is offered to a member of an evaluation committee or a client's staff when a decision concerning them is pending or foreseeable (award, permit, approval of a deliverable, payment).
• Cash and cash equivalents (prepaid cards, significant amounts of phone credit) are prohibited as gifts.
• Per diems and transport allowances paid to participants, including public officials, follow the rates set by the contract or funder, are paid against a signed attendance list and are never used to obtain a favour.

Facilitation payments are prohibited. Axiom Santé makes no payment, however small, to speed up or secure a routine formality (permit, visa, passage through a checkpoint). Only official fees, paid against an official receipt, are allowed. A person whose safety is threatened may comply with a demand; they then report it to Management without delay, and Management records it.

6. Procurement integrity and fair competition

• No agreements with other bidders on prices, market sharing or whether to bid.
• No use of confidential information obtained from a client, a public official or a competitor.
• No contact with evaluation committee members outside the channels set by the tender.
• Accurate CVs, references and certificates: Axiom Santé never proposes an expert without their written consent, never overstates their qualifications, experience or availability, and never includes a reference it cannot document.
• Any replacement of a key expert after award requires the client's prior approval.
• Commissions to agents or intermediaries are prohibited, unless declared to the client where its rules require or permit this.

7. Financial controls

Controls are proportionate to the size of the firm, without being relaxed on essentials:

• Dual approval. Every payment is prepared by one person and approved by another; nobody approves a payment of which they are the beneficiary.
• Supporting documents. No payment without an invoice, contract or purchase order, and evidence that the service was delivered.
• Field payments. Enumerators, supervisors and participants are paid preferably by bank transfer or mobile money, with reconciliation between the named list, phone numbers and transaction statements. Cash is used only where these means are unavailable, within an advance ceiling set in writing by Management for each assignment, against a named signature and a copy of an identity document where data protection rules allow.
• Advances. Every field advance is accounted for within a deadline set in advance; no new advance is granted until the previous one is settled.
• Reconciliations. Bank and mobile money accounts are reconciled every month.

8. Books, records and audit rights

Axiom Santé keeps accurate and complete books and records that faithfully reflect every transaction. No fictitious entries, off-book accounts, or backdated or altered documents are tolerated. Accounting records and supporting documents are kept for ten years, in line with the OHADA Uniform Act on Accounting Law and Financial Reporting (Article 24); records for each contract are kept for at least ten years after close-out, or longer where the contract requires.

The firm grants clients and funders, and the auditors and investigators they appoint, access to its accounts, records and documents relating to their funds, and the right to inspect and audit them. It imposes the same obligation on its subcontractors.

9. Whistleblowing and protection against retaliation

Anyone covered by section 2 who knows of, or reasonably suspects, a practice contrary to this policy must report it without delay. Clients, partners, participants and community members may also report. Reports may be anonymous.

Axiom Santé prohibits any retaliation (dismissal, non-renewal, withheld payment, intimidation) against a person who has reported in good faith, even if the facts are not confirmed. Retaliation is itself serious misconduct. The reporter's identity is protected and disclosed only with their consent or where required by law. A knowingly false report may lead to sanctions.

10. Investigation, client notification, sanctions and recovery

1. Management acknowledges every report within five working days, where the reporter can be identified.
2. It carries out a confidential review, or assigns it to a person independent of the facts; evidence is preserved.
3. Where a client's or funder's funds are or may be affected, Axiom Santé informs it promptly, within the timeframes set by the contract, and cooperates fully with any investigation it conducts.
4. Substantiated misconduct leads to proportionate sanctions: warning, suspension, termination of contract, exclusion from future assignments and, where appropriate, referral to the competent authorities.
5. Sums wrongly paid or diverted are recovered from those responsible; Axiom Santé reimburses the affected funds to the client or funder.

11. Responsibilities and review

Management adopts the policy, keeps the gifts register and exclusion list screening records, approves payments, handles reports and accounts to clients. Permanent staff apply financial controls and check proposals for compliance. Experts, enumerators and subcontractors sign an undertaking to comply with the policy before any assignment begins and receive a briefing during their initial training. The policy is reviewed every year, and sooner after an incident, a change in funder requirements or an audit recommendation. See also our PSEA policy and data quality policy.

12. Reporting and contact

Reports should be sent to info@axiomsante.org with the subject line "CONFIDENTIEL : Signalement" (Confidential: Report). These messages are handled by Management only. Anonymous reports are accepted. Please give as much detail as possible on the facts, dates, places, people involved and the assignment concerned. Reporting to Axiom Santé does not prevent anyone from contacting the client, the relevant funder or the competent authorities directly.