Education Action in Crisis Anti-Bribery Policy

Introduction

Education Action in Crisis (EAC) is committed to conducting its business in an ethical and transparent manner. We believe that bribery is a serious crime that undermines the integrity of our organization and the public trust. This policy outlines our commitment to anti-bribery and sets forth the procedures that we will follow to prevent and detect bribery.

Definition of Bribery

Bribery is the offering, giving, receiving, or soliciting of anything of value to influence the actions of an official or other person in charge of a public or legal duty. Bribery can take many forms, including but not limited to:

1. Offering or giving gifts, favors, or other inducements

2. Making payments to influence official decisions

3. Providing employment or other benefits in exchange for favors

Policy

EAC prohibits all forms of bribery. Employees, agents, and other representatives of EAC are prohibited from offering, giving, receiving, or soliciting anything of value to influence the actions of an official or other person in charge of a public or legal duty.

Reporting Concerns

Employees, agents, and other representatives of EAC who have concerns about possible bribery are encouraged to report them to any of the following individuals:

• The Executive Director

• The Board Chair

• The Human Resources Director

• The Ethics Officer

Concerns can be reported in writing or verbally. If you choose to report a concern in writing, you should do so by sending an email to the appropriate individual. If you choose to report a concern verbally, you should do so by speaking to the appropriate individual in person.

Investigation of Concerns

When a concern about bribery is reported, EAC will investigate the matter promptly and confidentially. The investigation will be conducted by a trained investigator who will interview the person who reported the concern, the person who is alleged to have engaged in the bribery, and any other relevant witnesses. The investigator will also review any available records, such as emails or text messages.

Response to Concerns

If the investigation finds that bribery has occurred, Education Action in Crisis (EAC) will take steps to address the situation. This may include taking disciplinary action against the person who is alleged to have engaged in the bribery, providing counseling to the person who reported the concern, or making changes to the workplace environment to prevent future incidents.

Confidentiality

All reports of bribery will be kept confidential to the extent possible. However, there may be times when it is necessary to share information with other agencies, such as law enforcement or regulatory bodies. In these cases, EAC will take steps to protect the confidentiality of the person who reported the concern as much as possible.

Enforcement

Education Action in Crisis (EAC) will enforce this policy consistently and fairly. Any employee, agent, or other representative of EAC who violates this policy will be subject to disciplinary action, up to and including termination of employment.

Conclusion

Education Action in Crisis (EAC) is committed to conducting its business in an ethical and transparent manner. We believe that bribery is a serious crime that undermines the integrity of our organization and the public trust.

If you have a concern of bribery or related case, please contact us at, whistleblow@educationactionincrisis.org