TAYOA Anti-Corruption Policy

1. Introduction and Purpose

1.1. Policy Statement Tanzania Youth and Adolescent Organization (TAYOA) has a zero-tolerance policy towards bribery and all other forms of corruption. We are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships, wherever we operate. This commitment is fundamental to our mission to empower youth and women and is essential for maintaining the trust of our beneficiaries, donors, partners, and the public.

1.2. Purpose The purpose of this policy is to:

• Set out our responsibilities, and the responsibilities of those working for us, in observing and upholding our position on bribery and corruption.
• Provide information and guidance to those working for us on how to recognize and deal with bribery and corruption issues.
• Ensure TAYOA’s compliance with all applicable anti-corruption laws and regulations in Tanzania.

2. Scope

This policy applies to all individuals working at all levels and grades, including board members, senior managers, employees (whether permanent, fixed-term, or temporary), volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners acting on behalf of TAYOA.

3. Legal Framework

This policy is designed to comply with the laws of the United Republic of Tanzania, primarily the Prevention and Combating of Corruption Act (PCCA) of 2007 and its subsequent amendments. The PCCA criminalizes various acts of corruption, including bribery, embezzlement, abuse of office, and trading in influence.

4. What is Corruption?

Corruption is the abuse of entrusted power for private gain. Bribery is a form of corruption and is defined as the offering, promising, giving, accepting, or soliciting of an advantage as an inducement for an action which is illegal, unethical, or a breach of trust.

Key Definitions:

• Bribe: A financial or other advantage offered, given, or received with the intention of inducing or rewarding the improper performance of a person’s duties.
• Facilitation Payment: A small, unofficial payment made to public officials to secure or expedite a routine or necessary action to which the payer is legally entitled. These are considered bribes and are strictly prohibited by this policy.
• Kickback: A portion of an awarded contract or fee paid back to the person who facilitated the transaction, usually as a result of coercion or a collusive agreement. This is a form of bribery and is strictly prohibited.
• Conflict of Interest: Occurs when an individual’s personal interests—or those of their family, friends, or close associates—could potentially influence their professional judgment or actions at TAYOA.

5. Prohibited Actions

It is strictly prohibited for any person covered by this policy to directly or indirectly:

• Give, promise to give, or offer a payment, gift, or any other advantage to anyone, including a public official, with the expectation or hope that a business advantage will be received in return, or to reward a business advantage already given.
• Accept a payment, gift, or any other advantage from a third party that you know or suspect is offered with the expectation that it will improperly influence a TAYOA decision or provide a business advantage.
• Give or accept kickbacks or facilitation payments.
• Make contributions to political parties or candidates on behalf of TAYOA.
• Engage in any activity that might lead to, or suggest, a breach of this policy.

6. Gifts, Hospitality, and Expenses

This policy does not prohibit normal and appropriate gifts, hospitality, and promotional expenses, so long as they are not intended to improperly influence a decision. However, the following rules must be observed:

• Gifts and hospitality must be reasonable in value, infrequent, and proportionate to the circumstances.
• They must not be offered or accepted in cash.
• They must be given or received openly, not secretly.
• They must comply with local laws.
• Any gift or hospitality offered or received with a value exceeding a nominal amount (e.g., 50,000 TZS) must be declared to your supervisor and recorded in TAYOA’s Gift and Hospitality Register.

7. Conflicts of Interest

All individuals under this policy have an obligation to avoid conflicts of interest. You must disclose any potential, perceived, or actual conflict of interest to your supervisor or the Human Resources department as soon as it arises.

8. Third Parties and Partners

TAYOA expects all its partners, contractors, and suppliers to adhere to anti-corruption principles. We will conduct appropriate due diligence on third parties before entering into a relationship and will include anti-corruption clauses in our contracts. Payments to third parties must be for legitimate services rendered and should be properly documented.

9. Record-Keeping

We must keep accurate financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties. All accounts, invoices, and other documents relating to dealings with third parties must be prepared with strict accuracy and completeness. No “off-book” accounts may be maintained to facilitate or conceal improper payments.

10. How to Raise a Concern (Whistleblowing)

You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be raised with:

• Your direct supervisor.
• The Human Resources Department.
• A designated senior manager or board member.

TAYOA is committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future.

11. Investigation and Consequences of a Breach

Any reported breach of this policy will be investigated thoroughly and confidentially. A violation of this policy will result in disciplinary action, which could include dismissal for gross misconduct. TAYOA reserves the right to terminate our contractual relationship with any third party if they are in breach of this policy. We will also report any suspected criminal activity to the relevant authorities, such as the Prevention and Combating of Corruption Bureau (PCCB).

12. Policy Acknowledgment

I have read, understood, and agree to comply with the TAYOA Anti-Corruption Policy. I understand that any violation of this policy may lead to disciplinary action, up to and including termination of my employment or contract, and potential legal proceedings.