Policy: Anti-Fraud and Whistle-blowing

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The Anti-Fraud and Whistle-Blowing Policy' intends to provide guidance to associates and partners and should be read in conjunction with all other Policies and procedures in relation to prevention, detection and reporting of fraud.

The Anti-Fraud and Whistle-Blowing Policy is designed to:

  • Promote standards of honest and fair conduct
  • Encourage prevention of fraud and corruption
  • Maintain strong systems of internal control
  • Promote detection
  • Pursue a zero tolerance policy and bring to justice anyone who commits acts of fraud or corruption
  • Recover any losses incurred


Whistle blowing

Any member of staff, contractor, partner or beneficiary considering that unethical behaviour has occurred is encouraged to report personally these infractions supported by any evidence and facts they can provide.

Overall responsibility for managing the risk of fraud is with the Board. Their Responsibilities include:

  • Undertaking a regular review of the fraud risks associated with each of the key organizational Objectives
  • Establishing an effective anti-fraud response plan, in proportion to the level of fraud risk identified
  • The design of an effective control environment to prevent fraud
  • Establishing appropriate mechanisms for, (a). Reporting fraud risk issues and (b). Reporting significant incidents of fraud or attempted fraud to the Board of Directors
  • Liaising with the Organization’s appointed Auditors
  • Liaising with the Finance team
  • Ensuring that all staff are aware of the Organization’s Anti-Fraud Policy and know what their responsibilities are in relation to combating fraud
  • Ensuring that appropriate anti-fraud training is made available to Directors, staff and volunteers as required
  • Ensuring that appropriate action is taken to minimize the risk of previous frauds occurring in future.

Persons currently responsible for receiving such complaints are Corina Drousiotou and Manos Mathioudakis. Personnel are also informed if needed they can bypass the above and make a complaint to the Board.

See the Full Text here File:FWC Antifraud Compliance.pdf.