HDF requires all its fund recipients (i.e. grantees, consultants and agents acting on behalf of HDF) to conduct their business honestly and appropriately at all times. Fund recipients should continuously seek to take the appropriate measures to identify such situations where this may be in question and make all reasonable efforts to rectify them.

A culture of openness within the workplace will help prevent such situations occurring. HDF expects its fund recipients to have a whistleblowing policy in place and to report any suspected wrongdoing to HDF immediately.

The purpose of this policy is to ensure that HDF fund recipients or related third parties (i.e. person or organisation who do not receive funds from HDF but are directly or indirectly affected by HDF programmes) are aware that they can raise any matters of genuine concern safe in the knowledge that HDF is committed to responding appropriately and effectively to all allegations of misconduct, both current and historical.

Whistleblowing is the disclosure of information, by a fund recipient’s employee or a third party, which relates to actual or suspected wrongdoing in the workplace including but not limited to fraud, other illegal or unethical conduct, sexual or physical abuse, misuse of funds or corruption.

Whistleblowing does not deal with any personal grievances staff may have regarding their employment (i.e. salaries, promotions and similar issues). Any such issues should be addressed within the fund recipient’s organisation).

HDF requires all its fund recipients to share HDF’s whistleblowing policy with its staff. This is to ensure staff are aware of the dedicated and confidential communication channel for reporting concerns of wrongdoing to HDF, if they feel or believe they cannot report them within their organisation.

Concerns may be submitted on a confidential basis and HDF will make the strongest effort possible to protect the informant’s identity. However, please be aware that serious allegations may require thorough investigation by authorities outside of the foundation, which may make it impossible for HDF to guarantee confidentiality in all cases.

Informants should also ensure they do not put their own safety at risk and HDF discourages whistle-blowers from conducting investigations themselves or publicly disclosing their name if they believe this could have a negative impact on their safety.

Reports of wrongdoing can be submitted via HDF’s whistleblowing form.

When reporting allegations of wrongdoing please provide the following information:

• Name of whistle-blower (optional)
• Phone number of whistle-blower (optional)
• Email of whistle-blower (optional)
• Organisation involved in wrongdoing
• Relationship of whistle-blower to the organisation
• Description of wrongdoing (including if possible: employee(s) allegedly involved in the wrongdoing, alleged perpetrator(s) and potential witnesses)
• Period of wrongdoing
• Supporting documentation

HDF will treat named and annonymous reports equally. Where contact details are provided, HDF will provide feedback to the whistle-blower and take all reasonable measures to ensure that no whistle-blower is subject to retaliation.

We will consider whether we can investigate any report by assessing the seriousness of the concerns raised, and whether we can sufficiently investigate the concerns based on the information provided.

HDF discourages anyone from knowingly sharing false information via the above communication channel.

Following the reporting of a concern of wrongdoing, HDF will where possible contact the whistle-blower and conduct a preliminary assessment to determine whether the facts reported can be investigated further. If this is the case, HDF or agents acting on behalf of HDF will conduct a thorough, impartial, accountable and timely investigation, with a view to gathering evidence and writing a conclusive report. The investigation will consist of reviewing documentation and conducting interviews. The investigation will be guided by the principles of objectivity, transparency, and fairness. Where required, external professional expertise and support will be contracted.

Who will conduct the investigation?

Based on the preliminary assessment and discussions with the whistle-blower HDF may decide not to conduct the investigation directly and to refer the case back to the fund recipient as appropriate.

HDF will investigate the case directly when:

• Senior management at the fund recipient is allegedly involved in wrongdoing
• Senior management at the fund recipient lacks capacity to investigate the case
• Senior management at the fund recipient lacks resources to investigate the case
• Senior management at the fund recipient cannot demonstrate a sufficient level of diligence and cooperation with the investigation of the case
• There are serious threats to the whistle-blower’s safety if the case is investigated internally

HDF is committed to responding appropriately and effectively to all allegations and suspicions of misconduct, both current and historical.

To this end, HDF will keep records of all allegations and suspicions of wrongdoing reported. The storage of any personal data will be in accordance with HDF’s Privacy policy. All cases will be reported to the HDF board in a timely manner.

Where appropriate and applicable HDF will:

• Refer the case to the local authorities
• Pursue all avenues to recover lost funds