(Implemented 2018, Updated 2025)

1. Introduction

The Gulf Centre for Human Rights (GCHR) is committed to applying the highest standards of ethical conduct and integrity in its activities throughout the world. Every employee and individual acting on GCHR’s behalf is responsible for maintaining the organisation’s reputation and for conducting the work of the organisation honestly and professionally. GCHR takes a zero-tolerance approach to bribery and corruption, and is committed to acting professionally, fairly and with integrity in all its dealings and relationships. Consistent with this, GCHR’s employees, officers, agents and others acting on GCHR’s behalf may not offer or accept bribes in any form.

2. Definitions

Corruption is commonly defined as the abuse of entrusted power for private gain. Bribery is a form of corruption and means:

• offering, promising, giving, receiving or soliciting money, gifts or anything else of value;

• as an inducement or a reward to a person to perform a relevant function or activity improperly. Bribery can occur in both the public and private sectors. The person receiving the bribe is usually in a position to influence the award or the progress of business or a service, often a public official or employee in the procurement department of a private entity.

3. Purpose and Principles

The purpose of this policy is to ensure that anyone acting on GCHR’s behalf:

• Promote a culture of honesty and openness among GCHR personnel and management.
• Be transparent in all work-related financial transactions.
• Never steal, misuse or misappropriate GCHR funds or property, ensuring that financial and other resources are used solely for the intended purposes.
• Create a work environment where communities and personnel can safely and confidentiality raise and report all serious concerns about suspected fraud and corruption.
• Never support individuals or entities involved in illegal activities.
• Conduct all business in accordance with internationally accepted practices and procedures and uphold the highest standards of accountability and transparency in relation to finances, management and governance, where relevant

4. Exceptional circumstances

Improper payments, gifts or inducements may be justifiable in exceptional circumstances. If a GCHR Staff member is faced with a threat to his/her health or personal safety, or that of another person, if a payment, gift or other inducement is not made, he/she should:

• make the relevant payment or gift or give the inducement without fear of recrimination;

and

• report the incident to the Executive Director as soon as possible.

5. Reporting procedures

Upon receipt of a complaint about bribery or corruption, GCHR will investigate and work to resolve all complaints in a confidential, timely, and thorough manner. While complete confidentiality cannot be guaranteed during the course of an investigation, every attempt will be made to use confidential information in a discreet manner. (See section 6 on No Retaliation and Whistleblowing below.)

Cooperation with any investigation is required of all employees as part of their job responsibilities. Any employee who fails to cooperate in an investigation may be subject to disciplinary action, up to and including termination of employment.

If the investigation of a reported or suspected occurrence of bribery or corruption reveals that an individual has not engaged in any form of bribery or corruption, management will inform both the individual and the complaining party (if their identity is known) that an investigation has been conducted and that no evidence supports the report or suspicion.

In the event an investigation reveals evidence that bribery or corruption has occurred, management will take whatever steps it deems necessary and appropriate to prohibit further acts of bribery or corruption, up to and including terminating the employment of an offending employee. These steps will be determined on a case by case basis commensurate with the situation, and with the requested level of anonymity. GCHR may also seek legal redress, including attorneys’ fees and costs, against any employee or other person who causes GCHR to incur any expense or liability as a result of prohibited behaviour.

Disciplinary action, up to and including termination of employment, may also be taken against any employee who witnesses bribery or corruption and does not report it as described above, including any manager who fails to report a complaint of bribery or corruption or who fails to take corrective action after being informed of any incident of bribery or corruption.

6. No retaliation and Whistleblowing

GCHR is committed to maintaining an environment in which individuals feel free to report all incidents of bribery or corruption. GCHR encourages the reporting of all occurrences of bribery or corruption under the procedures set forth in this policy. No retaliatory action will be taken against any person who in good faith reports conduct which he or she believes may violate this policy. Similarly, no retaliatory action will be taken against any individual who in good faith assists or participates in an investigation, proceeding, or hearing relating to a complaint. Any person who violates these provisions may be subject to discipline, up to and including termination of employment.

NOTE: For additional information, please see GCHR’s Procurement Policy, which governs contracts involving items, services (including personal services), supplies, equipment, programs, and real estate (i.e., purchases/sales and leases). It provides guidance on conflict of interest and on gifts, entertainment, hospitality and meals; as well as segregation of duties and supplier agreements.