1. Purpose:
The Anti-Corruption and Anti-Bribery Policy's first aim is to comply with the basic arrangements, principles, recommendations and criteria in local legislation, and the international legislation and good practices cited in this policy document.
The purpose of the Anti-Corruption and Anti-Bribery Policy is to ensure World Local Administration and Democracy Academy Foundation's compliance with anti-bribery and anti-corruption laws that apply to all of its fields of activity, ethical principles and universal rules, in addition to comply with its obligations concerning the prevention of financial crimes, to assess our business partners, operations and services using a risk-based approach in order to determine our strategies for mitigating potential risks, our relevant controls and measures, our operating rules and responsibilities, and to inform our workers accordingly.
This policy also aims to prevent laundering criminal revenues from bribery and corruption, to identify and eliminate as much as possible the conditions conducive to bribery and corruption, and to fulfil bribery and corruption obligations and commitments.
2. Definitions and Abbreviations
2.1. WALD: World Local Administration and Democracy Academy Foundation
2.2. Worker: World Local Administration and Democracy Academy Foundation personnel.
2.3. Service Provider: The personnel of a company (supplier, subcontractor, client, etc.) from/to which World Local Administration and Democracy Academy Foundation receives/provides services.
2.4. Corruption: Abuse of available resources and powers of an organization for direct or indirect personal gains.
2.5. Bribe: Benefits that a person gains through an agreement with a third person in order to do, not do, speed up or slow down a job in violation of his/her professional obligations.
Bribery and corruption may take many forms, including:
- Cash payments,
- Donations to political parties or charities,
- Commission fees,
- Social rights that are unequally used in violation of internal regulations,
- Gifts,
- Hospitality activities,
- Other benefits.
2.6. Public Officer: Includes persons who are temporarily, transitionally or permanently engaged in the performance of public activities (as defined in the Turkish Criminal Code) through assignment or election. "Public": All government bodies that serve the public.
3. Scope:
3.1. Our Anti-bribery and anti-corruption policy covers;
- Members of the WALD Board of Directors,
- WALD managers and workers,
- Affiliates, subsidiaries and workers,
- Companies from which we receive external services; people and organizations working under authority to represent WALD including consultants, financial advisors, lawyers, independent experts and external auditors.
3.2. This Policy is an integral part of the publicly announced WALD Code of Conduct, all WALD Policy Documents and the Disciplinary Regulations.
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4. Roles and Responsibilities:
4.1. Board of Directors
The Board of Directors is authorized and responsible to supervise the enforcement, monitoring and updating of the Anti-Corruption Policy, and to determine and enforce the notice, investigation and action mechanisms in case the arrangements are violated,
4.2. WALD Workers
WALD Workers are responsible
a. to ensure that the policies set by the Board of Directors are complied with,
b. Working in compliance with the internal and external legislation,
c. Informing the Internal Audit Department in case an action, activity or practice in violation of the policy is observed.
4.3. WALD Code of Conduct and Enforcement Method
4.3.1. In this regard, every worker, volunteer, service providing consultant, financial advisor, lawyer, independent expert and collaborating person and organization has to know the WALD Code of Conduct, and have to agree to these written rules with their signatures.
4.3.2. Corporate operations are clearly defined in terms of roles, powers and responsibilities. Operations and financial processes are carried out through double control mechanisms. All financial practices are recorded, and carried out within legal definitions and limits.
4.3.3. By design, every individual at WALD from service procurer to enforcer participate in feedback and decision processes. Every person in every position has to practice and comply with WALD Code of Conduct.
5. Policy and Implementation Principles
5.1. Bribery and Corruption
5.1.1 As an indicator of its sensitivity in terms of business ethics, WALD prepared this Anti-Bribery and Anti-Corruption Policy Bribery and corruption may take many forms, including:
a. Cash payments, political or other donations,
b. Commission fees,
c. Facilitating payments,
d. Social benefits,
e Gifts, representations and hospitality beyond those defined in the Ethical Principles and Code of Conduct,
f. Hiring a relative,
g. Other benefits,
h. Promotions, etc.
5.1.2 We hereby declare our commitment to carry out our activities in a fair, transparent, honest, legal and ethical manner in line with principles stipulated in this Policy Document.
5.1.3 In addition to our sensitivity in terms of anti-bribery and anti-corruption, we oppose bribery and corruption, and we don't tolerate activities that involve bribery and corruption. In this regard, WALD doesn't accept the offer, implication, reception or granting of bribes. As a principle, we don't continue business relations with third prties who wish to work with WALD through bribes. Our workers are not punished for delays or profit losses that arise due to their refusal to take or give bribes.
5.1.4 WALD acts in compliance with the legislations of foreign countries that have local legislations and activities for bribery and corruption.
5.1.5. We comply with all legal anti-bribery and anti-corruption arrangements in all of WALD's fields of activity.
5.2. Public Relations
Promising or implying to give any valuable gift and/or thing, any direct or indirect payment to a Public Officer in order to influence an official act or decision is not acceptable. Furthermore, our workers cannot directly or indirectly bribe public officers in order to gain advantage in public works. Accordingly, our workers hereby agree and undertake to comply with the Anti-Bribery and Anti-Corruption Policy of our foundation.
5.3. Agreements and Contracts
As WALD, we are committed to comply with this policy in agreements we enter, when beginning or maintaining a business relationship, or in public or private tenders.
5.4. Facilitating Payments
As WALD, we don't allow facilitating payments in order to secure or speed up a routine operation or process in public institutions (permit, license, tender procedures, etc.).
5.5. Donations and Gifts
Matters concerning donations and gifts in addition to their records at WALD are explained in detail in the WALD Code of Conduct. Our workers cannot accept or offer any gift that may damage their independence in their dealings with public officers, clients, suppliers and other business partners. We are careful to avoid situations that may cause or be perceived to cause conflicts of interest, and not accepting or giving gifts in such situations.
5.6. Record Keeping
The WALD accounting system of our foundation, and the rules it must follow are arranged in line with the relevant legislation and arrangements. We take care that:
a. All kinds of accounts, invoices and documents concerning relations with third parties (clients, suppliers, other service providers, etc.) are recorded and maintained in a complete, transparent, precise, fair and accurate manner,
b. Internal control mechanisms that will prevent off-record transactions are established,
c. No modifications are made on accounting or similar commercial records for any transaction, and the facts are not distorted.
5.7. Representation and Hospitality
Representation and Hospitality activities include;
a. Social activities,
b. Accommodation,
c. Dinner invitations.
WALD may engage in representation and hospitality activities in order to improve its relations, and for networking purposes. We strive to keep these activities reasonable. We take care that representation and hospitality activities are not carried out before a fundamental and important decision process. 5.8. Training and Communication
Our Anti-bribery and anti-corruption policy is announced to WALD workers, and is easily and continuously accessible in the organization's web site. We organize trainings to increase our workers' awareness on bribery and corruption.
6. Collaborating Organizations and Institutions:
Collaborating organizations and institutions and companies that provide goods and services have to comply with the principles of WALD's Anti-Corruption Policy, and other legal arrangements, work with people and organizations who don't comply will be ceased.
7. Implementation
7.1. WALD Board of Directors is responsible for informing workers, volunteers, experts and service providing third parties about the anti-corruption policy, establishing systems to monitor compliance with this policy, and regularly updating policy documents.
7.2. In case policy violations are identified and reported, it is essential that the Board of Directors establishes an investigation board that carries out the investigation in secrecy, and that the rights of the relevant people or organizations be protected during the investigation.
7.3. In agreements with private or legal persons, provisions stipulating that the works/agreements in force may be unilaterally terminated with good cause in case a behavior, attitude or action in violation of the Anti-Corruption Policy is identified , These provisions shall apply without exception in case of policy violation.
8. Validity
WALD Anti-Corruption Policy will enter into force after being approved by WALD Board of Directors. WALD Board of Directors is the application authority for all notices and complaints.