Accountability

Code of Conduct

Background

1. This Code of Conduct (the “Code”) applies to the directors, employees, interns, trainers, consultants, contractors and volunteers of Enrich (all such persons, whether or not they are paid or devote the whole or part of their time to Enrich, “Enrich persons”).

2. The Code comprises a code of behaviour and ethics which Enrich persons must follow when dealing with Enrich, with each other and with donors, clients (including migrant workers) and other third parties. It establishes general principles. Areas covered by the Code may be the subject of more detailed provisions and requirements established by other documents. The Code does not cover everything, but is an important element of the commitment of Enrich to ethical behaviour by itself and by Enrich persons.

3. The Code will be reviewed periodically.

General conduct and behaviour

4. Enrich persons must act with honesty, integrity and openness, in a responsible and professional manner and with courtesy and respect.

Mission

5. Enrich persons must understand and support (i) the mission and purpose of Enrich, (the “mission”), as established and amended from time to time by the directors of Enrich (the “board”) and (ii) the programmes of Enrich which are intended to implement the mission.

Legal compliance

6. Enrich persons must comply with all applicable laws and regulations.

Financial management

7. Those Enrich persons who are responsible for managing the financial affairs of Enrich must do so responsibly and prudently, in accordance with the following principles.

a. A significant proportion of the expenditure of Enrich must be on programmes designed to implement the mission.

b. The amount spent on administration must be sufficient to ensure that Enrich’s accounting, internal control, human resources and other financial and management systems are effective and that Enrich has competent and appropriately qualified employees.

c. Employees must be appropriately and reasonably compensated.

d. Fundraising costs must be reasonable, having regard to the factors which affect them.

e. Funds sufficient to implement the mission must be maintained, without the accumulation of excess reserve funds.

f. Spending practices and policies must be fair, reasonable and appropriate to the mission.

g. All financial reports must be prepared with due concern for fairness, accuracy and completeness.

Fundraising

8. Those Enrich persons who are responsible for fundraising must do so responsibly and prudently, in accordance with the following principles.

a. Fundraising materials should be prepared with due concern for fairness, accuracy and completeness, so that potential donors receive information (including the most recent published financial report of Enrich and the identity of the members of the board) relevant to a decision to donate, without material omissions.

b. Fundraising activities should be conducted in accordance with applicable legal requirements, including those relating to privacy and personal data.

c. So far as consistent with the mission, funds raised from donors should be spent in accordance with their expressed intentions.

d. Donors should receive appropriate acknowledgement and recognition, but any request by donors for confidentiality or to have their names removed from mailing lists should be honoured, subject to applicable legal requirements.

e. Those seeking donations should identify themselves as employees or volunteers of Enrich or as hired solicitors of donations.

f. Questions by donors and potential donors should be answered promptly, openly and truthfully.

Corruption and breaches of law

9. Enrich persons must not offer, solicit or accept anything of material value to or from other Enrich persons or any persons (including suppliers, contractors and migrant workers) who deal or interact with Enrich. This prohibition does not apply to gifts of a token nature (including the distribution to migrant workers of modest gifts in kind, for example soap and pens, which have been received by Enrich from corporate donors).

10. Enrich persons must report actual or suspected breaches by other Enrich persons of paragraph 9 or of any other law (including laws relating to theft, embezzlement and fraud). Breaches or suspected breaches by directors should be reported to the chair of the board (unless the breach or suspected breach is by the chair of the board, in which event it should be reported to the executive director of Enrich (the “executive director”)). All other breaches or suspected breaches should be reported to the executive director (unless the breach or suspected breach is by the executive director, in which event it should be reported to the chair of the board).

Entertainment and hospitality

11. Enrich persons should not accept entertainment or hospitality which is excessive (having regard to its value or frequency) or which will or may give rise to a conflict of interest (for example because the person providing the entertainment or hospitality is a supplier or contractor to Enrich) or an actual or perceived obligation to such person.

Inclusiveness and diversity

12. Enrich persons must promote inclusiveness and diversity in the recruitment, retention and promotion of Enrich persons and must not tolerate unlawful discrimination on any ground.

Confidentiality and use of property

13. Enrich persons must not, except as required by law, provide or make available confidential information of Enrich to anyone outside Enrich and must not misuse any such information. This obligation continues after Enrich persons cease to be Enrich persons. Confidential information is any information which is not in the public domain and which relates to Enrich, Enrich persons or the persons (including suppliers, contractors and migrant workers) with whom Enrich deals or interacts.

14. Enrich persons must not appropriate or use goods, services or information of Enrich for their personal benefit.

Record keeping

15. All books, accounts and records of Enrich must be created and (for so long as there is a legal or other requirement for such maintenance) maintained so as to reflect fairly and accurately and in reasonable detail the transactions of Enrich and its affairs. All expenses should be properly recorded in the books of Enrich and approved. Enrich persons must not make false or misleading entries or statements in the books, accounts and records of Enrich.

Conflicts of Interest

16. Conflicts of interest arise when the private interests of Enrich persons compete or conflict with the interests of Enrich or the duties of Enrich persons in their capacity as such. Private interests include the financial and other interests of Enrich persons and their relatives and other persons connected with them.

17. Enrich persons should, to the extent possible, avoid putting themselves in positions where conflicts of interest arise. Where this is not possible, such interests should be declared as soon as practicable.

Declarations by members of the board should be made in accordance with the articles of association of Enrich. Declarations by other Enrich persons except the executive director should be made to the executive director. Declarations by the executive director should be made to the board. Written records should be kept of all declarations of interest and of all decisions related to them.

Outside activities

18. Employees of Enrich who wish to take concurrent paid employment must seek the consent of the executive director (or, in the case of the executive director, the board).

Other policies

19. Enrich persons shall comply with the Enrich protection policy, the Enrich sexual harassment policy, the Enrich personal data protection policy and any other policies which Enrich adopts.

Compliance

20. Enrich persons who breach the Code may be subject disciplinary action, which may include termination of the employment or other relationship between Enrich and the relevant Enrich person. Where a criminal offence has been or is suspected to have been committed, reports may be made to the appropriate authorities, including the police.

Adoption

21. The Code was adopted by the board on 31st July 2017.