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Our Anti-Corruption Policy Document

01 January 2020 10:00

1.OBJECTIVE

 The Anti- Corruption Policy Document of the Federation of Associations for Barrier Free Living aims to clearly demonstrate the attitude of our Federation regarding the fight against corruption.

Policy Document, also  a guide setting ethical principles for all people, institutions, organizations, and suppliers in relationship with Federation, that are to provide goods or services, and it constitutes the essence of agreements with suppliers. 

None of the articles of our policy document conflict with the relevant laws that the Federation is subject to and does not alleviate the liability of the employee who is involved in the corruption and causing the corruption.

Our federation is determined to comply with national and international legal regulations, ethical and professional principles in order to prevent bribery and corruption. It aims to provide the highest standards in all its activities in line with the principles of honesty, transparency, accountability and objectivity.

 

2.SCOPE

Our Anti-Corruption Policy Document covers not only our Federation's executives and authorized boards, but also our members acting on behalf of our Federation, our volunteers and all our stakeholders with whom we work together.   

Our Policy Document is valid in the relations and activities of the associations that are members of our Federation.

Our Policy Document is valid in the relations and activities of our federation's parent organizations. .

All our Federation executives and parties acting on behalf of our Federation act in accordance with our Policy Document, and any business and all related procedures are prepared, implemented and audited in accordance with our Policy Document. 

However, in order for the Federation's directors and authorized boards to make sure that the federation and its members know the policies to be implemented, which policies they will adhere to and their responsibilities, the policy covers:

  • All Federation officials and employees, including the Federation's General Assembly Members and Board Members,
  • Persons and institutions of the Federation providing support services such as consultancy, advocacy and audit services,
  • Those who have any interest within the scope of the federation activities,
  • All suppliers, companies and all employees in this context,
  • All persons and organizations working directly or indirectly on behalf of the Federation

 

It is important to understand that all the practices and restrictions mentioned in the text of the Policy Document are also valid for the persons and organizations mentioned above. It should not be forgotten that if these persons and organizations act in any way that is not legal or unethical, the Federation may also be held legally responsible and / or may experience reputational risk.

Therefore, in all activities to be carried out, considering the general ethical principles, all policies and procedures and the text of this Policy Document, it should be ensured that all stakeholders, employees and officers act in accordance with these rules.

 

3.RESPONSIBILITY

3.1 Federation Board of Directors

The Board of Directors of the Federation is responsible at the highest level in the Anti-Corruption Policy Document. The Board of Directors provides appropriate conditions for the acceptance, dissemination, implementation and inspection of the policy document.

It takes measures to ensure the confidentiality and security of the persons who report the situations and processes that are contrary to the Policy Document. In this context, it ensures that the necessary studies and investigations are made within the framework of the legislation regarding the received complaints, notices and claims.

The Board of Directors ensures that audits are carried out and corrective measures are taken to ensure compliance with legal regulations, procedures and policies.

 

3.2 Managers and Employees

All employees and managers are to read and accept the Anti-Corruption Policy Document at the start of their duty and undertake to act in accordance with the principles in the policy text. The managers and all employees are obliged to inform the board of directors about the situations contrary to this policy document.

 

3.3 Ethics Committee

Formation: It consists of the Members of the Federation’s Supervisory (aka Auditory) Board and 2 members appointed by the Board of Directors. A member who claims to be in violation of this policy document cannot be included in the ethics committee. Alternate members may be assigned to the ethics committee in cases where an ethics committee cannot be established among permanent members.

Decisions taken by the Ethics Committee unanimously are binding for the board of directors. The board of directors has the power to take decisions for the implementation of decisions that are not taken unanimously.

In line with the request and need of the ethics committee, lawyer support is provided in order not to violate personal rights.

The duties of the Ethics Committee are as follows ;

  • Ensuring compliance with the Rules of the Policy Document and providing the necessary training,
  • Dissemination of ethical culture in the federation and member associations, and during their functioning and activities,
  • Increasing the awareness on the subject,
  • Implementation of the policy document,
  • Providing suggestions to the board of directors about the problems encountered
  • Making determination studies for notices, complaints and related notifications and submitting their decisions to the board of directors,

 

4.DEFINITIONS

4.1 Anything of Value

Any form of benefit,

  • Cash or cash equivalents, loans, gifts or awards,
  • Job offers or promises for the future (for the individual or his relatives)
  • Unfair and/or groundless discounts,
  • Accommodation / hosting services (travel expenses, hotel, meal, living expenses or travel and accommodation costs),
  • Vehicle use or allocation of homes,
  • Free tickets or discounts for events,
  • Services, personal favour or home renovation,
  • Opportunities created by the use of corporate commercial discounts or privileges used by the Federation.

 

4.2 Defining Corruption and Bribery

Corruption: It refers to the abuse of the authority acquired due to the current position, directly or indirectly, for personal or financial gain. The value of the bribe does not have to change hands for corruption to occur. Being offered or implied is sufficient for the violation of the policy.

Bribery: It means ensuring that a person performs an action that is contrary to the requirements of his / her duty or outside the normal work flow by means of doing, not doing, accelerating, slowing down a job, directly or indirectly, within the framework of an oral or written agreement, material or moral benefit to himself or to another person referred to by him. Benefits that can be considered as a bribe can take many different forms such as cash, gift, event invitation or ticket, debt forgiveness, charity donation. Although possible examples are listed below, similar acts will be regarded as bribe.

  • Cash,
  • Facilitating Payments,
  • Gifts,
  • Travel and Accommodation,
  • Charities and Political Donations,
  • Increasing or decreasing false prices in the tender (Fraudulent Bidding),
  • Illegal payments made through intermediaries and Third Parties,
  • Undeserved extra commissions, promotions,
  • In-kind favours and services,
  • Awarding projects without complying with legal processes,
  • Employing relatives,
  • Providing benefits to the family,
  • Unfair discounts and exemptions,

Receiving gifts, hosting, accepting donations and aids by the managers, representatives and employees who are specified as responsible within the scope of the Policy Document during the federation activities are only acceptable if these transactions are not personal, and only done by informing the board of directors before the transaction, transcribing them and recording the relevant commodities and amount in the federation accounts in accordance with the principle of transparency. Gifts and hosting services that are illegal, unrelated to our field of activity, unrelated to the activity and whose monetary value can be expressed as personal benefit are against this policy document.

 

Any benefit that transferred from second and third parties to the persons responsible within the scope of the policy document or to the second and the third parties from those responsible for the policies referred to in this document are regarded as violation of this policy document.

Even in matters not directly related to the activities of the Federation, if similar allegations occur in other activities of the relevant person, they can be examined provided they are submitted to the ethics committee.

 

5.POLICY

The Federation of Associations for Barrier Free brings the document into action as an indication of its sensitivity to ethics required for struggling in the name of disability rights. In addition to the ethical aspect of the issue, as any violation of the policy is essentially a criminal act, it is expected that those responsible will be sensitive to this issue and that they view it as part of their personal duties and responsibilities in connection with the struggle for the rights of the disabled.

The Federation of Associations for Barrier Free Living has adopted as a principle to comply with the laws and regulations within the scope of bribery and corruption, universal legal rules, ethical and professional principles in the areas where it operates and is represented. Our Federation acts with a "zero tolerance" approach against all kinds of corruption within the scope of this principle and undertakes to continue its activities in a fair, honest, legal and ethical manner. In this context, the federation prohibits all its components from any act to be possibly defined as corruption.

It does not matter whether or not parties has done something in return for monetary value,  whether the amount is high or low, or whether it is just proposed but not put into action, they not eliminate the contradiction to this document. National and international laws, regulations and principles are taken as basis in determining corruption and acts and behaviours within this scope.

In cases where corruption occurs, federation employees, managers or third parties (intermediaries) do not try to conceal corruption, bribery and similar situations. In such a case, the Ethics Committee is immediately notified. Two persons, one principal and one substitute, appointed among the members of the board of auditors, are responsible for the follow-up of the notifications. Notifications, related questions and requests can be forwarded to the address bilg@engelsizbilesenler.org.tr  

In case of violation of the Policy Document, Those who are found to have violated even one of the articles of this document are dismissed upon the proposal by the ethics committee and the approval of the board of directors. The information and documents that need to be sent to the judicial authorities are delivered immediately.

 

6.EFFECTIVE DATE AND CONDITION

Anti-Corruption Policy Document by The Federation of Associations for Barrier Free Living became valid and entered into force with decision no 05 dated 10/10/2020  by the Federation Board of Directors.