Business Ethics Policies

1. Policy Statement 

PinPoint Business Group is committed to conducting business with integrity, openness, transparency  and accountability; and to showing respect for human dignity and the rights of individuals and  communities. We have a “zero tolerance” approach to fraud and prohibit bribery in any form, whether  direct or indirect. This policy sets out our objectives and standards for ethical conduct and  performance, and covers the following: 

• Transparency 
• Human Rights 
• Labour Standards 
• Child and Vulnerable Adults Safeguarding 
• Individual Conduct 
• Conflicts of Interest 
• Bribery and Corruption 
• Fraud 
• Environment, Health and Safety 
• Corporate Governance 
• Whistleblowing 

Responsibility for adherence and implementation of our policy rests with the Chief Executive who is  answerable to the PinPoint Board of Trustees. The Chief Executive shall ensure the policy is applied in all  PinPoint activities and in dealing with development partners, agents, contractors and other third parties  with whom we have business relationships. 

The policy owner for editing purposes is the Chief Executive and the policy will be reviewed by the  Organization Systems Manager every year along with other policies and procedures to ensure they are in  line with best practice and meet the needs of our stakeholders and the delivery of our business objectives. 

PinPoint encourages any applicable party listed under section 2 to report actual, attempted or suspected  fraud and/or other forms of illegal activity and/or other breach of any of the provisions within this policy,  without fear of reprisal, to their line manager (if a member of staff), or to the Organization Systems Manager  or the Chief Executive, or by using the Whistleblowing Policy (Section 13). 

PinPoint will thoroughly investigate any allegations of breach of any of the provisions within this policy. PinPoint will address any instances of breach in accordance with the staff disciplinary procedure or  relevant contractual clauses with associated third parties. PinPoint has the right to dismiss or transfer to  other duties any personnel who breach any of the provisions within this policy or to terminate a contract  with third party found to be in breach of the same. 

Any investigation will be conducted with rigor and without regard to any person’s relationship to PinPoint,  position or length of service. Harassment, victimization or less favourable treatment of an employee will not be accepted on any grounds. PinPoint will provide appropriate protection for whistleblowers in accordance  with PinPoint’s Whistleblowing Policy. 

Once the internal investigation has been concluded and all relevant facts have been reasonably verified,  PinPoint will where appropriate inform the relevant donor(s) of the matter. This will normally be confidential and anonymous unless a public prosecution is proposed. 

All managers and supervisors have a duty to familiarise themselves with the types of breaches that might  occur within their areas of responsibility and to be alert for any indications of irregularity. Staff are  responsible for ensuring that PinPoint’s reputation and assets are protected against impropriety, reporting any known or suspected breach and assisting in the investigation of any suspected breach. 

2. Applicability Statement 

This policy applies to the Board of Trustees, officers, all employees, consultants, contractors, sub contractors, grant sub-awardees, suppliers, business partners and any other relevant parties. 

The Business Integrity and Ethics clauses are applicable to all individuals or organizations that enter into  contract with PinPoint. They are required to confirm that they have read and understood PinPoint’s Business Integrity and Ethics clauses and further confirm that they accept and agree with these principles  in performance of their services. For the purposes of the Business Integrity and Ethics clauses, “{Business  Partner}” shall mean the Consultant, Contractor, Individual or other entity as appropriate. 

3. Transparency 

We support the highest levels of transparency in our day-to-day decision-making, delivery of projects and  relationships with public bodies. Trust is essential to the delivery of our aims and objectives, we will: 

• Promote open book accounting 
• Prepare annual audited accounts certified by professional auditors at the end of PinPoint’s financial year and publish these on our website 
• Deliver open, honest, frequent and accessible communications via a range of suitable media • Encourage all staff to share information concerning risks, concerns and difficulties • Ensure compliance with relevant industry standards such as International Aid Transparency  Initiative (IATI) 

Furthermore, PinPoint and/or the member organization receiving funds on its behalf will provide donors  with regular financial reports and the progress of activities against programme targets. 

4. Human Rights 

We recognise the dignity and worth of all people and aim to promote social progress and a better quality of  life for all, particularly with respect to furthering PinPoint’s objectives.

We support the UN Global Compact, the Universal Declaration of Human Rights and the United Nations  Convention on the Rights of the Child and will work to ensure our partners and projects support the ethics  and articles laid out in these. We respect the human rights of our employees, partners, customers,  suppliers, contractors and the wider communities in which we operate. 

We respect the cultural values of individual societies and seek to align our operations with their traditions while always maintaining adherence to the objectives of this policy. 

5. Labour Standards 

We are committed to treating people fairly, recognizing their abilities and valuing their opinions. 

We will uphold equality of opportunity in all aspects of employment, recognising the diversity of our  workforce in the UK, USA, Austria, South Africa and internationally where we are delivering projects and  will make full use of the talents and resources available. 

We will reward employees fairly for the work they do. We are committed to the training and development of  our employees. 

We will not practice and do not condone any form of forced or compulsory labour, particularly child labour.

6. Child and Vulnerable Adults Safeguarding Policy 

Further information concerning child labour and child protection is detailed in PinPoint’s Child and Vulnerable Adults Safeguarding Policy. 

7. Code of Conduct 

Integrity and honesty are a fundamental part of all PinPoint relationships and all employees are expected  to adhere to the highest standards of business practice and personal conduct. 

We expect all employees to act honestly and ethically and in compliance with the laws and regulatory  requirements of the countries in which we are operating. Employees should consult with their line manager  if they are unsure whether a business practice is ethical or not. 

Employees and parties working on behalf of PinPoint are expected to treat customers and other stakeholders with respect, courtesy and professionalism. 

Written standards of conduct for the award and administration of contracts is contained within the  Procurement Policy.  

8. Conflict of Interest 

A conflict of interest exists if certain aspects of employees’ personal business or other interests may  adversely affect their motivation or performance in their job or lead to them making a decision which is to  the benefit of the individual, rather than to the benefit of PinPoint as an organization.

Employees are required to avoid any contacts that might lead to, or even suggest, a conflict of interest  between their personal activities and their responsibility to the company. Employees must report any known  conflicts of interest to the Chief Executive. 

All trustees and all staff, including consultants, are required to sign a declaration of interests. 

Where PinPoint’s interests have the potential to cause conflict with project delivery, these will be reported  to relevant partners. 

Conflicts of interest will be declared at the Trustee Board meetings and will be reported in the minutes.

9. Bribery and Corruption 

Bribery and corruption hurt the poor disproportionately, diverting resources intended for development and  humanitarian assistance, and increasing the costs of basic public services. They undermine economic  growth and are barrier to poverty alleviation and good governance. Often, bribery and corruption can  aggravate conflict and insecurity. 

In accordance with the UK Bribery Act 2010, PinPoint understands bribery to mean: the offering,  promising, giving, accepting or soliciting of money, gifts or other advantage as an inducement to do  something that is illegal or a breach of trust in the course of carrying out an organization’s activities. 

Bribery, whether offered or received, is unacceptable in all circumstances. Relationships with customers,  suppliers, officials and regulatory bodies shall be such that neither PinPoint’s integrity nor reputation would  be damaged or put at risk. 

We acknowledge the need to cooperate fully with the government and regulatory bodies. We will not make  contributions to political parties. We will not make, and will not accept, facilitation payments or kickbacks of  any kind, even if such payments are local practice or custom. Facilitation payments are typically small,  unofficial payments made to secure or expedite a routine government action by a government official. 

Kickbacks are typically payments made in return for a business favour or advantage. All individuals or  organizations bound by this policy must avoid any activity that might lead to, or suggest, that a facilitation  payment or kickback will be made or accepted by PinPoint. 

While we acknowledge that limited corporate hospitality is given and received as part of normal business  relationships, staff should avoid accepting hospitality or gifts, which might appear to place them under an  obligation. A register of all corporate hospitality given or received shall be maintained in each office – and  all offers, gifts or payments, whether accepted or not, must be entered into the register within 10 working  days and approved by the employee’s line manager. 

Any suspected malpractice and any concern that a conflict with this policy has taken place or is likely to  occur should be reported by following the procedure outlined in PinPoint’s Whistleblowing Policy (Section  13).

10. Fraud 

PinPoint will strive to prevent, detect, investigate and report fraudulent activity; we consider any acts of  fraud, misconduct, misrepresentation or embezzlement by its staff, contractors, suppliers, sub-contractors,  business partners, and any other relevant parties to be reprehensible. PinPoint will investigate all  instances of actual, attempted and suspected fraud and will seek to recover funds and assets lost through  fraud. Perpetrators will be subject to disciplinary and/or legal action. 

Fraud is broadly defined as any intentional false representation, failure to declare information or abuse of  position, which is carried out to make gain, cause loss or expose another to the risk of loss. This can  include theft, the misuse of funds or other resources or more complicated crimes such as false accounting as well as the supply of false information and intentional misrepresentation affecting the financial  statements by one or more individuals among management, staff or third parties. 

Misconduct may include but is not limited to: falsifying timesheets or other documents, abuse of sick time,  theft. Embezzlement includes the misuse or stealing of funds or other organization resources; billing for  services not performed and other irregular billing practices; inflating charges or services or products; false  claim; and other irregularities. 

PinPoint policies and procedures are an important way to help protect against fraud and compliance with these is mandatory for all staff and trustees.  

Any weaknesses in the control environment identified during audit and the measures proposed or taken to  address these will be reported to the Trustees for corrective action. 

11. Environment, Health, Safety and Security 

We are committed to meeting our environmental, health, safety and security responsibilities to our  employees, clients and the wider public. Separate standards/policies will be developed to cover the delivery  of these responsibilities. 

12. Corporate Governance 

PinPoint is comprised of three distinct legal entities operating as a coordinated enterprise  and a unified management structure. The governing boards of the three legal entities normally meet  together. 

The three legal entities are: 

• PinPoint UK, incorporated on 16 November 2006 as a private limited company and subsequently  registered as a charity governed by a Board of Trustees. 
• PinPoint USA, incorporated in the state of Delaware on 25 April 2007 with 501(c)(3) non-profit status 
• PinPoint South Africa, incorporated on 23 April, 2008 with charity status

The Trustees have overall legal responsibility for PinPoint. They meet quarterly, or more often when  necessary. 

PinPoint UK staff oversees and implements day-to-day activities on behalf of the Trustees. The UK staff  also monitors and oversees all business activities and ensures adherence to PinPoint’s business procedures and policies in their implementation. 

13. Whistleblowing Policy 

Purpose and Scope 

The purpose of this policy is to enable employees to raise concerns about malpractice in connection with PinPoint. It provides a framework for genuine concerns to be raised internally without fear of  repercussion. It also provides a mechanism to protect PinPoint and its employees against uninformed or  vexatious allegations. 

This procedure applies to all PinPoint employees, consultants and sub-contractors employed directly or indirectly by PinPoint. It covers situations where employees become concerned about malpractice at work by employees, managers and contractors acting on behalf of PinPoint. These concerns may be about acts  or omissions that have led or could lead in future to any malpractice within PinPoint. 

This procedure applies to disclosure by an individual (described in this procedure as “Discloser”] who is an  employee or contract worker engaged by PinPoint. 

Under legislation, the Discloser is entitled to specific rights relating to the disclosure of certain types of  information (or “blowing the whistle”). The protection applies to the disclosure of information of a specified  category to a specified person in specified circumstances. 

Qualifying disclosure 

A “qualifying disclosure” means any disclosure of information that, in the reasonable belief of the worker  making the disclosure, tends to show one or more of the following: 

• that a criminal offence has been committed, is being committed or is likely to be committed • that a person has failed, is failing or is likely to fail to comply with any legal obligation to which he or  she is subject 
• that financial impropriety, malpractice or fraud has occurred, is occurring or is likely to occur • that a miscarriage of justice has occurred, is occurring or is likely to occur 
• that the health or safety of any individual has been, is being or is likely to be endangered • that the environment has been, is being or is likely to be damaged 
• that improper conduct or unethical behaviour has occurred, is occurring or is likely to occur • that information tending to show any matter falling within any one of the preceding paragraphs has  been, is being or is likely to be deliberately concealed

However there will not be protection for the disclosure if the worker commits an offence by making the  disclosure, or it is a disclosure in respect of which legal professional privilege would apply. 

Qualifying procedures 

In order for the disclosure to be protected the Discloser must make it by one of the following methods or  procedures: 

• to PinPoint’s Chief Executive, Communications Director, or legally responsible person or appropriate  person authorised by PinPoint to receive disclosures 
• to a legal advisor of PinPoint 
• to a member of the PinPoint Board of Trustees  

Any disclosure should be in writing and should include as much supporting evidence as possible. The Discloser  should not talk to anyone else about the disclosure as this may prejudice any future investigation. All  disclosures will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation. 

Upon conclusion of the investigation, the Chief Executive or the Communications Director will recommend  what further steps are to be taken. Such recommendations may include one or more of the following: 

• the matter be investigated further internally by the Board or by external auditors or investigators  appointed by the Board; 
• the matter be reported to the police; 
• the matter may be subject to internal disciplinary proceedings 
• if perpetrated by an external party, they be barred from further with work PinPoint for a definite  period or indefinitely 

A recommendation of no further action may be made if the Chief Executive or Communications Director is: 

• satisfied after investigation that malpractice has not occurred or is not likely to occur • aware that the matter is already subject to legal proceedings, or has already been referred to the  police or other public authority 
• aware that the matter is already (or has already been) subject of proceedings under one of  PinPoint’s other procedures 
• satisfied that the Discloser does not have sufficient evidence that malpractice within the meaning of  this procedure has occurred, is occurring or is likely to occur 
• satisfied that the Discloser is not acting in good faith 

Any recommendations under this procedure will be made by the Chief Executive or Communications  Director to the PinPoint Board. The Communications Director will be responsible for ensuring the  implementation of any recommendations. 

The Discloser will be informed of the steps taken, or if no steps are taken, the reason for this. 

In addition, disclosure is protected if it is to an individual unconnected with PinPoint, such as the police or the  media. In this case the Discloser will only be protected if:

• the matter has previously been raised with PinPoint or a prescribed person, or it has not been so  raised because the employee reasonably believes that he or she will be victimised 
• the worker has a reasonable belief, in the absence of a prescribed person, that a complaint to the  employer would result in evidence being concealed or destroyed 
• the information has already been disclosed to the employer or prescribed person • the information is serious enough to justify bypassing one of the other specified procedures • the disclosure is made in good faith, in the reasonable belief that the claims are substantially true, not  for the Discloser’s personal gain 
• it is “reasonable in all the circumstances” to make the disclosure. 

Safeguards 

While all practical steps will be taken to protect the identity of the Discloser, the Discloser must accept that  in some circumstances their identity could be revealed. Confidentiality of the Discloser’s identity cannot  therefore be guaranteed. 

The Discloser will not be formally identified unless the Discloser consents in writing or there are grounds to  believe that the Discloser acted maliciously. In the absence of consent or grounds, the Discloser will only  be formally identified if: 

• this is a legal obligation 
• the information is in the public domain 
• it is to a lawyer for the purposes of obtaining legal advice 
• where it is necessary as part of a formal investigation 

Any documentation (paper and electronic) filed in relation to the matter will be kept secure and any  prepared documentation, as far as practicable, will not reveal the identity of the Discloser. 

Protection against detriment for making a Disclosure 

No detriment will be imposed and no disciplinary action will be taken against the Discloser because of  disclosure made in good faith in accordance with this procedure. 

PinPoint may take disciplinary action in cases where there are grounds to believe that a disclosure has been made maliciously or where external disclosure is made in breach of this procedure without reasonable grounds.