Fighting Corruption With Transparency

Transparency is a state of comprehensive information and accountability. Transparency depends on open communication – especially in critical situations. This creates clarity and truthfulness in dealing with entrusted and one’s own resources. Through a conscious separation of responsibilities, appropriate control mechanisms and the participation of various interest groups and actors, compliance with applicable statutes and procedural rules is guaranteed.

To this end, EMW has initiated various preventive measures.

• The following should generally apply as minimum standards
  • Financial transfers and project development as well as personnel exchanges shall take place within the framework of written agreements.
  • Decision-making and implementation competencies within the framework of financially relevant actions are to be separated in terms of personnel.
  • Administrative capacities are checked for their suitability and appropriateness and strengthened through ongoing training and further education as well as appropriate personnel measures (capacity building).
  • Full-time employees and volunteers are required to comply with existing codes of conduct.
  • The acceptance of gifts or other benefits above a certain monetary value or outside the limits of what is culturally customary must be prohibited.
  • Criminally relevant acts must be reported to the responsible law enforcement authorities.

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• In finances, the following should be noted
  • The principle of dual control applies to payment transactions.
  • Accounting must be carried out in accordance with generally applicable national or international standards. A regular external financial audit should take place.
  • Internal control mechanisms, e.g. unannounced cash audits, should be established.
  • Transactions relating to an exchange in money or other benefits must be documented in writing.

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• Further Measures
  • Areas at risk of corruption should be identified by means of a risk analysis. In areas particularly at risk of corruption and identified accordingly after a risk analysis, it may be advisable to rotate personnel at certain intervals to be defined.
  • Common guidelines should be developed for financial officers of the ministries, member churches and partners, and regular training and exchange should be carried out.
  • Arrangements should be made to prevent abuse of office.

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• Measures to investigate cases of corruption

  Information on matters suspected of corruption must be forwarded to a responsible person. The person in charge must make their own efforts to clarify the matter and/or involve other persons or bodies. Appropriate structures and procedural regulations must be created. A neutral person can be appointed to protect whistleblowers.

  An orderly procedure should enable objective clarification and ensure the individual protection of whistleblowers. Persons from the voluntary supervisory bodies or external third parties are suitable for appointing an oversight officer. They must have unhindered access to all relevant data.

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• Penalties

  In the event of proven corruption or the deliberate abuse of whistle blowing, appropriate action must be taken. A distinction must be made between penalties imposed on individuals and those imposed on institutions within the scope of their respective responsibilities and competencies.

  Possible penalties against individuals:

  • Penalties under labor and employment law
  • Removal from office in the case of honorary or otherwise elected or appointed persons
  • Repayment of funds from own pocket
  • Mandatory reporting in the case of criminal proceedings.

  Possible actions with respect to institutions:

  • Reduction or withholding of funds or allocations
  • Reallocation of funds or allocations to repair the damage
  • Agreeing on “penalties” that can be paid or deducted from payments for violations
  • In the most extreme case, termination of the partnership.