Anti-Fraud Anti-Terror Policy
1. Purpose of Policy
Enov8 is committed to taking all reasonable efforts to ensure that any funds or in-kind support we provide to our partners and third parties is not being directed towards Terrorist Activities (defined below) and to mitigate against fraud, theft, misappropriation, money laundering and the misuse of funds and corruption in the transfer of funds from Enov8.
2. Scope of Policy
This policy applies to:
(a) all programs and projects that Enov8 funds or provides in-kind support in Australia and overseas.
(b) all Enov8 personnel (being Enov8 Board members, employees, volunteers, contractors and consultants); and
(c) all partner organisations involved in implementing our projects and programs, including international partners.
(d) For the purposes of this Policy, Terrorist Activities relates to activities of: a person, group or organisation who is listed as a terrorist in a list published by the Australian government, the World Bank and any government list of the relevant country in which a program or project is located; and
(e) organisations and individuals for whom Australia has imposed sanctions under the Charter of the United Nations Act 1945 (Cth) and regulations made under the Act, the Anti Terrorism Act 2001 (Cth), the Autonomous Sanctions Act 2011 (Cth) or Criminal Code Act 1995 (Cth).
3. Policy Principles
(a) We will use its best endeavors to ensure that partner organisations and parties that receive Enov8 funds or in-kind support and implement Enov8 program and project activities will not breach any Australian laws, including laws relating to anti-terrorism financing, money laundering or funds misuse.
(b) We will use best efforts to promote and implement best practice principles and practices to safeguard against funds misuse.
(c) We will embed this policy within our organizational culture and create awareness in relation to counterterrorism by distributing and explaining this policy to Enov8 personnel.
(d) Enov8 will take all reasonable steps to understand the level of risk it may be exposed to in relation to terrorism financing or money laundering and, where risk is evident, ensure that appropriate precautions are in place.
4. Policy in Practice
(a) Due diligence of International Partners
- Each assessment and approval of an International Partner and approval of project funding shall involve an assessment of the risk of terrorism financing.
- Enov8 will take all reasonable steps to undertake due diligence on each of our prospective International Partners, including:
- confirming their identity, credentials and good standing,
- checking the organisation name and names of their key personnel and management against relevant lists of terrorist organisations and sanctioned individuals and organisations published by the Australian Government, World Bank and by the relevant country in which the program or project is located, and
- regular project visits and reviews by Enov8 staff members.
- We will keep records of due diligence checks and re-appraise all partners on an annual basis where our partnership has a term of over a year.
(b) Anti-terrorism / Anti-Money-Laundering practices of approved International Partners
- Enov8 will require all International Partners to comply with the laws of the countries in which they are operating relating to anti-terrorism financing or money laundering.
- We will require our International Partners to have written policies and practices in relation to the avoidance of terrorism financing and funds misuse that are consistent with our policy principles. If our International Partner does not have such a policy or to the extent that its policy is less stringent or inconsistent with Enov8’s, we will require the International Partner to adopt Enov8’s policy.
(c) Payments and transfer of funds
- All Enov8 grant payments shall be made through regulated financial institutions to known beneficiaries or approved partners.
- We will maintain detailed records of all payments of all fund transfers to third parties and International Partners.
(d) Monitoring and Reporting
- Enov8 shall monitor and evaluate the activities carried out by International Partners to ensure that grants are expended on the purpose for which they are given.
- Where the Board of Enov8 has assessed an International Partner at high risk of Terrorism Financing, extra precautions will be put in place by the Board.
- Any suspicious activity will be notified to the Directors of Enov8 immediately.
5. Policy Revision History
Policy reviewed by the Enov8 Board on January 2020.