Trust is good, but careful supervision is so much better – and this is particularly true when it comes to ensuring that all donations are used for their intended purpose. Kindernothilfe conducts comprehensive internal and external audits, as do our local partner organisations that work with us to conduct projects on site.
The Kindernothilfe Anti-Corruption Code of Conduct serves as a policy for preventing corruption within Kindernothilfe and among its partner organisations. Ombudspersons are equally important in combating corruption. They act independently of the organisation and gather information whenever there are reasonable grounds to suspect corruption connected with Kindernothilfe projects.
1. Internal monitoring
Internal monitoring and suitable internal supervision systems ensure that workflows proceed correctly, laws and regulations are respected and corrupting and corrupt behaviour is prevented.This includes process-independent monitoring carried out by Kindernothilfe internal auditors, as well as the monitoring of the Executive Board by the supervisory body. The Kindernothilfe Diaconic Corporate Governance Code, approved in 2007, is designed to contribute to this effort. It defines how the Association’s bodies cooperate with each other and how the Executive Board is monitored.
2. External audits
Kindernothilfe’s operational and financial management, its partners, project partners and projects are regularly audited by independent bodies. This requires accounting standards and financial statements, comprehensive financial reporting and the preparation of an annual financial statement that is audited and tested by an independent auditor. Internal monitoring mechanisms are an integral part of these audits. Fundamental principles of accounting and compiling financial statements, financial reports and annual reports by partners, project partners and projects are explained in the relevant valid KNH guidelines. It is also possible to conduct random audits on the use of funds at the partner, project partner and project levels.
3. Effective monitoring thanks to a clear division of responsibilities
Kindernothilfe’s Statutes and relevant rules of procedure stipulate a clear division of responsibility among the organisation’s bodies. The members of the Association elect the Board of Trustees, which appoints the full-time members of the Executive Board, and advises and supervises them. Furthermore, Kindernothilfe has introduced a modified version of the Good Governance Code of the Protestant Agency for Diaconia and Development, which specifies the distribution of responsibilities, and requires that the Executive Board present its annual and budget planning to the Board of Trustees for approval.
1. Project supervision and assistance
Kindernothilfe pursues two key objectives here: First, it ensures that the funded projects steadily improve the living conditions of children, their families and communities. Second, it safeguards that project funds are used effectively and efficiently. To achieve this, Kindernothilfe has developed the following key components:
2. Project application
Every new project requires a proposal that includes information on the project partner, goals, target groups, monitoring, risks and financing. All applications are reviewed: from a content-related and a professional perspective by the relevant international division; and from a financial perspective by the controlling department.
3. Contractual basis
A cooperation agreement defines the collaboration with partners and projects. This contract contains a general section with rights and obligations, and a special section that covers agreements on goals and areas of focus.
4. Annual plan
All projects and partners have to present a plan with goals, benchmarks, requirements and activities along with a budget. This plan is mandatory to receive funding. No payments will be made without a plan that meets all requirements.
5. Acknowledgment of receipt
A written acknowledgment of receipt of payments is required (date, amount in euros and in the local currency).
6. Progress report
Projects should report on their progress. All projects that annually receive more than €75,000 must present semi-annual reports that provide information on deviations from plans and budgets.
7. Project visits
Projects and partners are regularly visited. Kindernothilfe staff evaluate project progress, design and management. They also audit the accounting, financial management and financial statements. Furthermore, they conduct workshops to improve the work. If projects fail to use funding as agreed, or even misappropriate funds, those responsible will be held accountable (repayment of funds and, in some cases, legal prosecution).
8. Annual report
All projects are required to present annual reports that include information on activities and whether objectives have been met. These reports are supposed to illustrate both successes and difficulties/problems. The annual report serves as the basis for the project report that is sent to all sponsors every year.
9. Annual financial statement
All projects and partners are required to submit annual financial statements (balance sheet, profit-and-loss statement) that must be reviewed by an independent auditor and include an audited report. All annual financial statements are evaluated and comprehensive audits are conducted randomly. If an annual financial report is not submitted in a timely manner, fails to meet the required standards, or does not include an unqualified auditor’s opinion, no payments will be made until these shortcomings are remedied.
Stephan Konrad
(Lawyer)
Mauerstraße 8
33602 Bielefeld
E-mail: ombudsperson.kindernothilfe@gmail.com
In 2019, with the adoption of a completely revised integrity and anti-corruption policy, the establishment of an anti-corruption team and a comprehensive case management system, Kindernothilfe laid down new cornerstones in its working commitment on behalf of integrity and against corruption.
Text: Guido Oßwald, David Kowertz, Juan Fagiani
Together with Dr Marie-Carin von Gumppenberg, we developed a workshop concept for partner organisations that would enable partners to identify themselves with their corruption risks and develop their own appropriate preventive measures. The first two workshops took place in Ethiopia and Somalia in late 2019 and early 2020.
Stephan Konrad, a lawyer from Bielefeld, was appointed by the Administrative Board as ombudsperson with the task of preventing and combating corruption. Whistle-blowers can contact him directly to report suspected cases – also anonymously with guaranteed protection of personal rights – at ombudsperson.kindernothilfe@gmail.com.
Six cases of suspected corruption were reported to the anti-corruption team in 2019, compared to fourteen in 2018. A further six cases were reported by April 2020. Of the cases of suspected corruption reported in 2018, six were either not confirmed or could not be proven. Of the six cases reported in 2019, three are still under investigation, while in the other three cases, the suspicions were either not confirmed or could not be proven. In 2020, examination of two cases has been completed: suspicion was not confirmed. Investigation of the remaining four cases has begun.
When investigating cases of suspected corruption, whistle-blower protection is just as important to us as the presumption of innocence principle. The investigation of suspected corruption is normally complex and time-consuming: are the accusations sufficiently specific to justify an on-site inspection by staff from Kindernothilfe's country co-ordination office or an external auditor appointed by Kindernothilfe? Is there sufficient evidence to enable a judgement to be reached and/or justify the imposition of sanctions?
Sanctions may include the repayment of misappropriated funds, the dismissal of staff of the organisations concerned and the immediate termination of working co-operation. Fundamentally, the latter would come into effect when corrupt and corrupting behavior has permeated an entire organisation and the respective committees and/or committee members are involved (systemic corruption).
Our anti-corruption Ombudsperson:
Stephan Konrad Bielefeld
ombudsperson.kindernothilfe@gmail.com
