Anti-Fraud, Anti-Bribery & Anti-Corruption Policy
Zero-tolerance controls for bribery, fraud, kickbacks, facilitation payments, embezzlement and other improper business practices.
View all policies↗What this policy is designed to do.
To protect clients, donors, employees and Lion & Leo from fraud and corruption by combining clear prohibitions with financial controls, due diligence, reporting and investigation.
Who it applies to: All personnel, agents, consultants, suppliers, subcontractors and other parties acting for or on behalf of Lion & Leo.
The standards we expect in practice.
These principles guide decisions, conduct and day-to-day execution across the relevant parts of our business.
Never offer, request, authorize, receive or conceal a bribe, kickback or improper benefit.
Do not make facilitation payments except where an immediate threat to health or safety leaves no reasonable alternative, and any such event must be reported promptly.
Maintain honest books, records, invoices, expense claims and procurement documentation.
Investigate credible concerns impartially and preserve relevant evidence.
Cooperate with legitimate client, donor, auditor and regulatory review requirements.
Controls that turn policy into evidence.
Controls are scaled to the nature, value and risk of the activity rather than treated as a one-size-fits-all checklist.
Segregation of duties across purchasing, approval, receipt and payment activities.
Approval thresholds and dual authorization for higher-risk transactions.
Supplier due diligence, sanctions screening and background checks proportionate to risk.
Documented audit trails, invoice verification and periodic internal review.
External audit and independent assurance where required by law, contract or governance practice.
Clear ownership matters.
Finance protects payment controls and financial records.
Procurement applies competitive and documented sourcing procedures.
Managers escalate suspected fraud rather than trying to resolve serious cases informally.
Compliance coordinates investigations and corrective action for material allegations.
How to raise a concern.
Suspected fraud or corruption should be reported immediately through the confidential channels described in the Whistleblowing & Reporting Policy, including compliance@lionleo.net.
Reports made honestly and in good faith should be protected from retaliation. Confidentiality is maintained as far as possible while still allowing a fair assessment or investigation.
Policies that work together.
Governance controls overlap by design. These related policies provide additional context for this topic.