1.1 POLICY STATEMENT
Civil Development Organization –CDO has a “zero tolerance” policy towards fraud, bribery Civil Development Organization –CDO has a “zero tolerance” policy towards fraud, bribery, and corrupt practices.
All CDO employees regardless of the position, ethnicity, and race, partners and vendors have a duty to protect the assets of CDO and to comply with relevant laws of the below anti-fraud policies.

2 2.1 PRINCIPLES
CDO’s policy on Fraud, Bribery and Corruption is guided by the principles of:
Integrity: CDO will act in a principled and honest fashion.
Legitimacy: CDO will abide by all applicable laws relating to fraud, bribery and corruption.
Timeliness: CDO staff will report suspicions of fraud, bribery or corruption in a timely manner.
Fairness: CDO will investigate allegations of fraud, bribery or corruption in an even-handed way.

2.1.2
CDO maintains systems and procedures to ensure that the risks of fraud, bribery and corrupt practices are minimized and that any incidents are detected, investigated, reported and dealt with effectively where they do occur.

2.1.3
Where fraud, bribery or corrupt practices are detected, CDO will investigate and take appropriate action against staff, consultants, volunteers, partners, vendors and any other party or individuals

2.1.4
CDO staff, consultants, contractors, interns and volunteers must immediately report any suspicion of fraud, bribery or corrupt practices to the Country Director (if at country office), to the Regional Director (if at regional office) or to a member of the senior leadership team (if at the center).
If they do not feel able to report directly to the General Director, staff can report to their line manager or to the email address of cdo.headoffice@yahoo.com

2.1.5
Failure to report fraud, bribery or corruption will be treated as a serious issue and may result in disciplinary measures being taken.

2.1.6
Attempted fraud, bribery or corruption will be treated with the same seriousness as actual fraud, bribery or corruption under this policy.

2.1.8
Partners and suppliers must report to CDO and take action against fraud, bribery or corruption occurring in their organization and must immediately report to their contact at CDO (or the relevant CDO Country Director) any suspicion of fraud, bribery or corruption within CDO.

Word/Term
Definition
“Bribery” or “corrupt practices” or “corruption”
Offering, giving, receiving or soliciting a financial or other advantage in connection with the performance of a position of trust or a function that is expected to be performed impartially or in good faith.
Behavior which amounts to bribery and corrupt practices includes but is not limited to:

Paying or offering a bribe: where an individual improperly offers, gives or promises any form of material benefit or other advantage, whether in cash or in kind, to another person in order to influence their conduct in any way.

Receiving or requesting a bribe: where an individual improperly requests, agrees to receive or accepts any form of material benefit or other advantage, whether in cash or in kind, which influences or is designed to influence his or her conduct in any way.

Receiving a so-called ‘graft’ or ‘facilitation’ payment: where an individual improperly receives something of value from another party for performing a service or other action that they were required by their employment to do anyway. For example: where a member of staff at a partner refuses to issue the required travel authorizations without a personal payment also being made.

Nepotism or patronage: where an individual improperly uses their employment to favor or materially benefit friends, relatives or other associates in some way. For example, through the awarding of contracts, jobs or other material advantages.

Embezzlement: where an individual improperly uses funds, property, resources or other assets that belong to CDO or a connected organization or individual. For example, a member of staff using building contractors who have been employed to work on a CDO project to work on their own personal property.

Receiving a so-called ‘kick-back’ payment: where an individual improperly receives a share of funds or a commission from a supplier as a result of their involvement in a corrupt bid or tender process.

Collusion– where an individual improperly colludes with others to circumvent, undermine or otherwise ignore CDO’s rules, policies or guidance. For example, where an individual tries to fix the level of a tender in order to bring it below a certain threshold which has been set by CDO.
Abuse of a position of trust– where an individual improperly uses their position within CDO or a connected organization to materially benefit themselves or any other party. For example, an individual intentionally accessing confidential material they are not entitled to or passing confidential information (such as the contents of a tender bid) to a third party.

“Fraud”
An act of deception intended for personal gain or to cause loss to another party (even if no such gain or loss is in fact caused). Behavior which amounts to fraud includes but is not limited to:

False invoicing: where an individual knowingly creates or uses invoices that are false in any way.
Expenses fraud: where an individual dishonestly uses the expenses system to pay money or other benefits that the recipient is not entitled to.

Procurement fraud: where an individual engages in any dishonest behavior relating to procurement or tendering process, e.g. falsely created bids or quotes.

Supply chain fraud: where an individual misdirects or steals goods, forges stock records, or creates fictitious companies through which to channel payments.

Payroll fraud: where an individual dishonestly manipulates the payroll system to make unauthorized payments to him or herself or another. For example, by creating ‘ghost’ employees or dishonestly increasing one’s own salary.

Tax or duty evasion: where an individual knowingly avoids payment of a tax or other duty that he or she is aware should be paid.

False accounting: where an individual deliberately enters false or misleading information into any form of accounting or financial record.

Forgery: where an individual dishonestly creates or alters a document so that the information contained in it is incorrect or in any way misleading.

Bank or cheque fraud: where an individual dishonestly manipulates any banking system or record (such as a cheque, bank statement or electronic transfer).

Brand fraud: where an individual dishonestly uses CDO’ name, branding or documentation for unauthorized or illegitimate ends.

Conflict of interest: where an individual knowingly has an undisclosed business interest in an entity involved in a commercial relationship with CDO.

Theft: where an individual dishonestly takes or appropriates any item of property that belongs to another.
ACKNOWLEDGEMENT OF RECEIPT OF ANTI-BRIBERY AND ANTI-CORRUPTION POLICY
I affirm that I have read and understood the CDO Anti-Fraud policy.

INTRODUCTION:
This document outlines the policies and procedures established to ensure that Civil Development Organization is recognized as a child safe organization.
Children who come into contact with CDO and its Programs are safeguarded to the maximum extent from child abuse and sexual exploitation.
Everyone associated with CDO must be fully aware of the problem and risks of child abuse and sexual exploitation
All representatives of CDO must demonstrate the highest standards of behavior towards children both in their private and professional lives. They must not abuse the position of trust that comes with being a part of the CDO family. They must do all that they can to prevent, report and respond appropriately to such issues.
The Policy includes mandatory requirements that apply to everyone in all aspects of the CDO International’s work whether in advocacy and campaigns, development programs or humanitarian and emergency responses.

DEFINITION:
A child is defined as anyone under the age of 18 years
Child abuse consists of anything which individuals, institutions or processes do or fail to do which directly or indirectly harms children or damages their prospect of safe and healthy development into adulthood
Sexual exploitation means any actual or attempted abuse of a position of vulnerability, differential power, or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another.

THIS POLICY APPLIES TO:
CDO staff, whether national, international, full time, part time or engaged on short-term contracts, e.g. consultants, researchers etc.
Volunteers, trustees and board members of CDO, Civil Development members and other representatives.
Staff and representatives of partner agencies and any other individuals, groups or organizations who have a formal/contractual relationship with CDO that involves any contact with children (unless it is formally agreed that a partner organization may enforce its own safeguarding or protection policy).
Donors, journalists, celebrities, politicians and other people who visit CDO programs or offices in order to make contact with children must be made aware that this Protocol applies to them while visiting our programs or offices.
All of the above must act in accordance with this Protocol in both their professional and their personal lives.
All staff and partners are expected to abide by this policy in their personal and professional life. Failure to do so can lead to disciplinary action including termination of contract.

BEHAVIORTOWARDS CHILDREN
Staff, consultants, contractors, partners and other representatives must never:
1. Hit or otherwise physically assault or physically abuse children
2. Engage in sexual activity or have a sexual relationship with anyone under the age of 18 years regardless of the age of majority/consent or custom locally. Mistaken belief in the age of a child is not a defense.
3. Develop relationships with children which could in any way be deemed exploitative or abusive.
4. Act in ways that may be abusive in any way or may place a child at risk of abuse.
5. Use language, make suggestions or offer advice which is inappropriate, offensive or abusive
6. Behave physically in a manner which is inappropriate or sexually provocative
7. Sleep in the same bed as a child with whom they are working.
8. Work or stay in the same room alone with a child whom they are working unless exceptional circumstances apply and previous permission has been obtained from their line manager.
9. Do things for children of a personal nature that they can do themselves.
10. Condone, or participate in, behavior of children which is illegal, unsafe or abusive
11. Act in ways intended to shame, humiliate, belittle or degrade children, or otherwise perpetrate any form of emotional abuse.
12. Discriminate against, show unfair differential treatment or favor to particular children to the exclusion of others.
13. Spend excessive time alone with children away from others
14. Place themselves in a position where they are made vulnerable to allegations of misconduct

This is not an exhaustive or exclusive list. Staff, consultants, contractors, partners and other representatives should at all times avoid actions or behavior which may allow behavior to be misrepresented, constitute poor practice or potentially abusive behavior.
It is important for all staff, consultants, contractors, volunteers, partners and other representatives in contact with children to:

1. Be aware of situations which may present risks and manage these
2. Plan and organize the work and the workplace so as to minimize risks
3. As far as possible, be visible in working with children
4. Ensure that a culture of openness exists to enable any issues or concerns to be raised and discussed
5. Ensure that a sense of accountability exists between staff so that poor practice or potentially abusive behavior does not go unchallenged
6. Talk to children about their contact with staff or others and encourage them to raise any concerns
7. Empower children – discuss with them their rights, what is acceptable and unacceptable, and what they can do if there is a problem.
8. Maintain high personal and professional standards.
9. Respect the rights of children and treat them fairly, honestly and with dignity and respect
10. Encourage participatory practice with children which develops their own safeguarding capacity

REPORTING AND RESPONDING TO CONCERNS
All CDO, other representatives and staff of partner agencies must report all concerns including both specific reports and unconfirmed concerns regarding child abuse or sexual exploitation where the alleged perpetrator is a member of staff, other representative or staff of a partner agency.
The first priority of any staff member to whom child protection concerns are reported must be the immediate safety and welfare of the child.
There are no exceptions to child protection policy. Any breach of this policy is investigated in accordance with Local Procedures and this Child Protection Policy and is stated to be a disciplinary offense which can result in dismissal in all staff contracts.

ACKNOWLEDGEMENT OF RECEIPT OF CHILD PROTECTION POLICY
I affirm that I have read and understood the CDO Child protection policy.

Employees of CDO are obliged to, at all times, comply with all applicable governmental laws and regulations. CDO will not conduct the activities of employees whom they achieve results through violation of the law or unethical business dealings. This includes any payments for illegal acts, indirect contributions, rebates, and bribery. CDO does not permit any activity that fails to stand the closest possible public security. All business conduct should be well above the minimum standards required
By law or donors or standards specified in CDO s internal policies. Accordingly, employees must ensure that their actions cannot be interpreted as being, in any way, in contravention of the laws and regulations governing the CDO’s operations.
Employees uncertain about the application or interpretation of any legal requirements should refer the matter to their supervisor, who, if necessary, should seek appropriate legal advice.

General Employee Conduct
CDO expects its employees to conduct themselves in a businesslike manner. Drinking, gambling, fighting, swearing, smoking hookah, and any similar unprofessional activities are strictly prohibited while on the job.
Employees must not engage in sexual harassment or conduct themselves in a way that could be construed as such, for example, by using inappropriate language, keeping or posting inappropriate materials in their work area, or accessing inappropriate materials on their computer.

Equality and Ethical Values
Employees must not disrespect any individual person for their sex, religion, color or race. All members of CDO must feel responsible for respecting all the ethical values inside the community, and must attain equality between all races and religions. Also CDO must respect the rights of minorities, and must maintain their ethical values within the communities.
In case of working with refugees/IDPs, employees must maintain equality between all refugees/IDPs of different race and religion and the employees must maintain equality values between the local people and the refugees in case of conflicts.

Conflicts of Interest
CDO expects that employees will perform their duties conscientiously, honestly, and in accordance with the best interests of the Organization. Employees must not use their positions or the knowledge gained as a result of their positions for private or personal advantage. Regardless of the circumstances, if employees sense that a course of action they have pursued, or are presently pursuing, or are contemplating pursuing may involve them in a conflict of interest with their employer, they should immediately communicate all the facts to their supervisor.

Outside Activities, Employment, and Directorship
All employees share a serious responsibility for the Organization’s good public relations, especially at the community level. Their readiness to help with religious, charitable, educational, and civic activities brings credit to the Organization and is encouraged. Employees must, however, avoid acquiring any business interest or participating in any other activity outside the Organization that would, or would appear to:
• Create an excessive demand upon their time and attention, thus depriving the Organization of their best efforts on the job.
• Create a conflict of interest – an obligation, interest, or distraction – that may interfere with the independent exercise of judgment in the Organization’s best interest.

Relationships with Clients and Suppliers…
Employees should avoid investing in or acquiring a financial interest for their own accounts in any business organization that has a contractual relationship with CDO, or that provides goods or services, or both to CDO if such investment or interest could influence or create the impression of influencing their decisions in the performance of their duties on behalf of CDO.

Gifts, Entertainment, and Favors
Employees must not accept entertainment, gifts, or personal favors that could, in any way, influence, or appear to influence, business decisions in favor of any person or organization with whom or with which the CDO has, or is likely to have business dealings. Similarly, employees must not accept any other preferential treatment under these circumstances because their positions with CDO might be inclined to, or be perceived to place them under obligation to return the preferential treatment.

Kickbacks and Secret Commissions
Regarding the Organization’s business activities, employees may not receive payment or compensation of any kind, except as authorized under CDO’s business and payroll policies. In particular, CDO strictly prohibits the acceptance of kickbacks and secret commissions from suppliers or others. Any breach of this rule will result in immediate termination and prosecution to the fullest extent of the law.

Organization Funds and Other Assets
Employees who have access to Organization funds in any form must follow the prescribed procedures for recording, handling, and protecting money as detailed in CDO’s policies and procedures or other explanatory materials, or both. CDO imposes strict standards to prevent fraud and dishonesty. If employees become aware of any evidence of fraud and dishonesty, they should immediately advise their supervisor or seek appropriate legal guidance so that CDO can promptly investigate further.
When an employee’s position requires spending Organization funds or incurring any reimbursable personal expenses, that individual must use good judgment on the Organization’s behalf to ensure that good value is received for all expenditures.
Organization funds and all other assets of the Organization are purposed for CDO only and not for personal benefit. This includes the personal use of organizational assets, such as computers.

Organization Records and Communications
Accurate and reliable records of many kinds are necessary to meet CDO’s legal and financial obligations and to manage the affairs of the Organization. CDO’s books and records must reflect in an accurate and timely manner all business transactions. The employees responsible for accounting and recordkeeping must fully disclose and record all assets, liabilities, or both, and must exercise diligence in enforcing these requirements.
Employees must not make or engage in any false record or communication of any kind, whether internal or external, including but not limited to:
• False expense, attendance, production, financial, or similar reports and statements
• False advertising, deceptive marketing practices, or other misleading representations
Dealing With Outside People and Organizations
Employees must take care to separate their personal roles from their Organization positions when communicating on matters not involving CDO business. Employees must not use organization identification, stationery, supplies, and equipment for personal or political matters.
When communicating publicly on matters that involve Organization business, employees must not presume to speak for CDO on any topic, unless they are certain that the views they express are those of the Organization, and it is CDO’s desire that such views be publicly disseminated.
When dealing with anyone outside CDO, including public officials, employees must take care not to compromise the integrity or damage the reputation of CDO or any outside individual, business, or government body.

Prompt Communications
In all matters relevant to customers, suppliers, government authorities, the public and others in CDO, all employees must make every effort to achieve complete, accurate, and timely communications – responding promptly and courteously to all proper requests for information and to all complaints.
Privacy and Confidentiality
When handling financial and personal information about customers or others with whom the Organization has dealings, observe the following principles:
• Collect, use, and retain only the personal information necessary for CDO’s business. Whenever possible, obtain any relevant information directly from the person concerned. Use only reputable and reliable sources to supplement this information.
• Retain information only for as long as necessary or as required by law. Protect the physical security of this information.
• Limit internal access to personal information to those with a legitimate business reason for seeking that information. Use only personal information for the purposes for which it was originally obtained. Obtain the consent of the person concerned before externally disclosing any personal information, unless legal process or contractual obligation provides otherwise.

Consequences and Penalization
Failure to implement any of the above requirements, CDO will take immediate actions by either warning the employee(s), or inflicting a penalty on the employee(s), or in case of high deviations from the law in immediate termination of the employees’ contract(s).

ACKNOWLEDGEMENT OF RECEIPT OF CODE OF CONDUCT POLICY
I affirm that I have read and understood the CDO code of conduct policy.

Civil Development Organization’s Commitment
Civil Development Organization, its main office and all its sub offices Iraq drop-in centers, community centers, and any other entities controlled by Civil Development Organization adopts a zero tolerance approach to the abuse of drugs and alcohol in the workplace.
Drug and alcohol abuse has a direct negative impact on the workplace and on the strength of our business as a whole. Employees under the influence of drugs are at a significantly higher risk of being breaching the internal laws of CDO and the human rights and threatening the quality and safety of fellow workers and the operation.
The Drug & Alcohol Policies of Civil Development Organization, its main office and all its sub offices in Iraq, drop-in centers, community centers, and any other entities controlled by Civil Development Organization are established to provide a safe workplace for all Employees and protect the best interests of the organization, its’ beneficiaries and the general public.
All Employees have a shared responsibility for workplace safety and are expected to look out for other Employees, partners, visitors, beneficiaries.

Scope
For the purposes of this policy, “CDO” includes all their related, affiliated and subsidiary entities in Iraq.
This policy applies to all employees.

Purpose
Drug and alcohol abuse has a direct negative impact on the workplace and on the quality of work as a whole. Employees under the influence of alcohol or drugs are at a greater risk of being injured and sustaining more serious injuries than Employees who are sober. The purpose of this policy is to outline protocols for managing and reducing risks associated with alcohol and drug use in the workplace and during work hours.

Implementation
This policy governs the manufacture, distribution, possession, use or sale of a “controlled substance,” including, but not limited to any of the following items, by any individuals, while on organization Facilities:

• “Controlled substance” means a drug or substance listed in applicable KR-I laws.
• “Illegal or unauthorized drugs” means any drug which is not legally obtainable, which is legally obtainable but has not been legally obtained, outdated prescriptions and any other chemical substances which may affect an individual’s mood, senses, responses, motor functions or alter or affect a person’s perception, performance, judgment, reactions or senses.
• Drug-related paraphernalia.

All persons and items including bags, lockers, and briefcases, are subject to search while on organization offices.
Excluded from this policy are drugs prescribed in the KR-I by Ministry of Health licensed medical practitioner and over-the-counter drugs and inhalants obtained in the KR-I provided that:
• The drugs and inhalants have been legally obtained and are being used for the purpose for which they were prescribed or manufactured; and
• Workplace safety, performance and efficiency are not affected by the employee’s use of the drugs or inhalants.
Employees and other individuals are strictly prohibited from reporting to work or working under the influence of unauthorized or illegal drugs or alcoholic beverages.
Consumption of alcohol, in moderation, at CDO approved or sponsored functions are not prohibited by this policy. In these special circumstances, it is extremely important that all employees exercise moderation, proper judgment and comply with all laws and traffic and safety regulations.
Not with standing, employees are strictly prohibited from operating a CDO vehicle or performing CDO work in a vehicle while intoxicated.
Consent to Search and to Conduct Drug and Alcohol Testing
An employee’s consent to submit to drug and alcohol testing upon request is required as a condition of continued employment. CDO may require a breath or blood test, urinalysis or other form of testing to determine the presence of drugs or alcohol.
An employee’s refusal or failure to submit to alcohol or drug testing shall be considered insubordination.
An admission of being impaired by or under the influence of a controlled substance, illegal drug or alcohol or of having a controlled substance illegal drugs, or alcohol within his/her body, and is grounds for disciplinary action up to and including termination of employment.
The submission of an adulterated, substituted or diluted sample is considered a refusal to submit.

Random Testing
CDO may randomly select employees to submit to a drug or alcohol test to ensure compliance with this policy. The random selection process is completely objective and anonymous. Employees who are randomly selected may be selected for random testing in the future. Employees randomly selected for testing will be required to submit to testing by urine, blood, saliva strip, breath analyzer, or other method.
Reasonable Suspicion Testing and Search
If CDO has reasonable suspicion that an employee has used, possessed or distributed any prohibited items, CDO reserves the right to conduct searches in any work area on or off Organization Facilities for such items. The search may include any person entering Organization Facilities, personal effects, lockers, organization or personal vehicles, baggage or any other items present on Organization Facilities.

Post-Incident Testing and Search
CDO reserves the right to administer drug and alcohol testing or demand that employees submit to drug and alcohol testing immediately after a work-related incident. An employee’s refusal to submit to testing is considered insubordination and it may be presumed that the employee was intoxicated or under the influence of drugs or alcohol at the time of the incident.

Return to Work and Fitness for Duty Testing
CDO does not offer return to work or fitness for duty testing, substance abuse expert evaluations or treatment for employees that refuse to submit or fail a drug or alcohol test.
No search or testing of any employee will be conducted without the employee’s consent. However, an employee’s consent to search and testing is required as a condition of employment and refusal to consent will result in disciplinary action up to and including termination of employment.
Employees Who Test Positive or Refuse to Test
Any employee or a contractor having business with CDO who refuses to submit to a urinalysis test, breath test, blood test or search or who is found in possession of or under the influence of any such illegal or unauthorized items without satisfactory explanation will be banned from any Organization Facility and subject to disciplinary action up to and including immediate termination of employment or contract.

Positive Test Results
Refusals to test or positive test results for illegal drugs or alcohol under this policy will be result in immediate termination of employment.

ACKNOWLEDGEMENT OF RECEIPT OF DRUG AND ALCOHOL ABUSE POLICY
I affirm that I have read and understood the CDO Drug and Alcohol Abuse Policy and I understand that if I:
(a) engage in the use, sale, possession, distribution or transfer of a controlled substance, illegal drug or alcohol while at work, on Organization Facilities or on work duty,
(b) am discovered with a controlled substance, illegal drug, or drug paraphernalia in my possession during work hours or on Organization Facilities, or
(c) am under the influence of or impaired by a controlled substance, illegal drug or alcohol during work hours or while on Organization Facilities without the permission from a CDO Organization in charge person, that I may be subject to disciplinary action up to and including immediate termination of employment.

I agree to fully comply with and abide by all rules and regulations set forth in the Drug and Alcohol Abuse Policy as a condition of continued employment by CDO. I further understand that CDO has the right to request, in accordance with its Drug and Alcohol Abuse and Policy that I submit to a drug and alcohol test as a condition of continued employment. I understand that refusal to consent to such a drug and alcohol test is insubordination and otherwise may be regarded as an admission by me of being impaired by or under the influence of a controlled substance, illegal drug or alcohol and is thereby grounds for disciplinary action up to and including immediate termination of
employment.

INTRODUCTION:
Sexual Exploitation and Abuse (SEA) is Particular forms of GBV that have been reported in humanitarian contexts, specifically alleged against humanitarian workers.

Sexual Exploitation: Any actual or attempted abuse of a position of vulnerability, differential power, or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another

Sexual Abuse: The actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions.

OVERVIEW:
This section outlines the CDO Policy and Procedures for Preventing and Responding to Sexual Exploitation and Abuse, including the mandatory awareness-raising training and reporting procedures. All CDO staff members are expected and required to understand what SEA is, engage in behavior that respects and fosters the rights of beneficiaries, and report in good faith any SEA allegations, concerns or suspicions, or retaliation related to SEA.

THIS POLICY APPLIES TO:
CDO staff, whether national, international, full time, part time or engaged on short-term contracts, e.g. consultants, researchers etc.
Volunteers, trustees and board members of CDO, Civil Development members and other representatives.
Staff and representatives of partner agencies and any other individuals, groups or organizations who have a formal/contractual relationship with CDO that involves any contact with children (unless it is formally agreed that a partner organization may enforce its own safeguarding or protection policy).
Donors, journalists, celebrities, politicians and other people who visit CDO programs or offices in order to make contact with children must be made aware that this Protocol applies to them while visiting our programs or offices.
All staff and partners are expected to abide by this policy in their personal and professional life. Failure to do so can lead to disciplinary action including termination of contract.

DESCRIPTION:
The CDO Standards of Conduct states:
CDO staff members shall provide humanitarian assistance and services in a manner that respects and fosters the rights of beneficiaries. For this reason and because there is often an inherent and important power differential in the interactions between staff members and beneficiaries, CDO strongly discourages staff members from having any sexual relationships with beneficiaries.
In addition, CDO staff members shall protect against and prevent sexual exploitation and sexual abuse (SEA) of beneficiaries. Abusive and exploitative sexual activities with beneficiaries are absolutely prohibited.
This is not an exhaustive or exclusive list. Staff, consultants, contractors, partners and other representatives should at all times avoid actions or behavior which may allow behavior to be misrepresented, constitute poor practice or potentially abusive behavior.

BASIC STANDARDS AND PROCEDURES:
In order to protect the most vulnerable populations and to ensure the integrity of CDO’s activities, the following specific standards shall be followed:
1. Exchange of money, employment, goods, assistance or services for sex, including sexual favors or other forms of humiliating, degrading or exploitative behaviour, is prohibited.
2. Sexual activity with children (persons under the age of 18) is prohibited, regardless of the age of majority or age of consent locally. Mistaken belief regarding the age of a child is not a defence. This prohibition shall not apply if the CDO staff member is legally married to someone under the age of 18 but over the age of majority or consent in both the CDO staff member and spouse’s country of citizenship.
3. Sexual exploitation and abuse among CDO staff members are prohibited.
4. Using the services of prostitutes or sex workers is prohibited, regardless of the legal status of prostitution in the laws of the CDO staff members’ home country or duty stations. This prohibition extends to the use of prostitution outside working hours, including while on Rest & Recuperation and home leave.
The above-mentioned acts are not intended to be an exhaustive list. The above-mentioned acts, as well as other types of sexually exploitive or sexually abusive behavior constitute serious misconduct and, as such, are grounds for disciplinary measures, including summary dismissal.
All CDO staff members, particularly managers, are obliged to create and maintain an environment that prevents SEA. The failure of CDO staff members to appropriately prevent or follow-up on claims of SEA, may be reflected in the staff members’ performance appraisal and constitute grounds for disciplinary measures.
As set out in the policy, every CDO staff member shall:
Read and ensure that they understand:
1. A Report in good faith SEA allegations, concerns or suspicions or retaliation related to SEA that they have witnessed, or know of, by other CDO staff members, employees or other personnel of CDO Contractors, any other person working on CDO projects, or by people employed by or working for other organizations.
2. Cooperate fully with those responsible for investigating a report or complaint about SEA.

CDO head office and all the offices and branches in Iraq shall, within their area of responsibility:
1. Serve as focal points for the prevention of sexual exploitation and abuse (“PSEA focal point”), who will inform CDO staff members under their supervision of the contents of rules and policy of CDO, remind them of CDO’s zero tolerance policy for SEA at every appropriate opportunity, and ensure that their staff receive a copy of this policy.
2. Act as role models in making every reasonable effort to create and maintain an environment that assists in preventing SEA by CDO staff members;
3. Take appropriate action upon receipt of any report or complaint about SEA allegations, concerns or suspicions or retaliation related to SEA.
4. Ensure that each agreement signed with an CDO Contractor includes the CDO standard clause on PSEA, or receive approval from the Gender Coordination Unit if the standard clause cannot be used owing to exceptional circumstances;
5. Ensure that all CDO staff members under their supervision participate in available training on PSEA and related issues on a regular and timely basis and as needed;
6. Take reasonable steps to prevent and monitor SEA-related retaliation against and by all CDO staff members under their supervision;
7.Discuss PSEA, as appropriate, as part of the Staff Evaluation System process.
When PSEA focal points receive any SEA report or complaint from any source, including from the local referral complaint mechanism, they should promptly report the issue to the HR department in CDO head office.
Reference to the above and below rules and instructions about CDO SEA policy I hear by and
I undertake not to abuse the power and influence that I have by virtue of my position over the lives and wellbeing of persons of concern.
I will never request any service or favour from persons of concern in return for protection or assistance. I will never engage in any exploitative relationships – sexual, emotional, financial or employment-related – with beneficiaries or other persons of concern.
Should I find myself in such a relationship with a beneficiary that I consider non-exploitative and consensual, I will report this to my supervisor for appropriate guidance in the knowledge that this matter will be treated with due discretion. I understand that both my supervisor and I have available to us normal consultative and recourse mechanisms on these issues.
I will act responsibly when hiring or otherwise engaging persons of concern for private services. I will report in writing on the nature and conditions of this employment to my supervisor.

ACKNOWLEDGEMENT OF PROTECTION AGAINST SEXUAL EXPLOITATION AND ABUSE POLICY
I affirm that I have read and understood the CDO policy of Protection against Sexual Exploitation and Abuse