## Anti-Fraud and Anti-Corruption Policy

## Source details

**Canonical URL:** [Anti-Fraud and Anti-Corruption Policy](https://www.imf.org/-/media/files/about/ethics/policy/anti-fraud-anti-corruption-011725.pdf)

## Other formats

- [Markdown version](/-/media/files/about/ethics/policy/anti-fraud-anti-corruption-011725.pdf.md)
- [Structured JSON version](/-/media/files/about/ethics/policy/anti-fraud-anti-corruption-011725.pdf.json)

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### Overview
- The International Monetary Fund (the Fund) affirms a commitment to integrity and ethical conduct in its activities and operations.
- Fraudulent and corrupt practices:
  - undermine the Fund’s financial integrity by depleting funds, assets, and other resources necessary to fulfill the Fund’s mandate;
  - can damage the Fund’s reputation and diminish trust in its ability to deliver results in an accountable and transparent manner;
  - may affect personnel effectiveness, motivation, morale, and the Fund’s ability to attract and retain talent.
- The Fund does not tolerate fraud and corruption involving Fund personnel, vendors, and Third-Parties.
- The Office of Internal Investigations (OII) is mandated to receive, assess, and investigate allegations of misconduct, including fraud and corruption.
- All Fund employees must report Prohibited Activities internally to OII or anonymously through the Integrity Hotline; retaliation against employees who report misconduct is prohibited under Fund policies.

### Scope and Application
- The Policy covers:
  - All activities and operations of the Fund.
  - All Fund employees, including: (i) staff; (ii) contractual employees; (iii) short- and long-term experts; (iv) local employees; (v) interns; and (vi) volunteers (collectively “Fund personnel”).
  - Vendors, suppliers, sub-contractors, and other Third-Parties engaged by the Fund.
- The Policy:
  - defines each Prohibited Activity;
  - provides guidance on prevention policies and procedures;
  - outlines responsibilities and framework for preventing Prohibited Activities;
  - describes reporting and investigation procedures; and
  - identifies disciplinary and recovery actions resulting from findings of Prohibited Activities.
- Fund personnel unsure of obligations should seek advice from the Ethics Advisor.

### Definitions and Examples of Prohibited Activities
- Prohibited Activities defined in section 3.1 include:
  - Fraud
    - Definition: Any act or omission, including a misrepresentation, that knowingly or recklessly misleads, or attempts to mislead a person or entity to obtain a financial or other benefit from the Fund, or to avoid an obligation for oneself or for a third party.
    - Examples:
      - knowing fraud: providing false documents to support payment of an Education Allowance (EDA) benefit for which the employee is ineligible;
      - reckless fraud: failing to update records after becoming ineligible, resulting in repeated payments.
  - Theft
    - Definition: Unauthorized taking of anything that belongs to another individual or entity.
    - Example: taking a colleague’s wallet from their office.
  - Corruption
    - Definition: Offering, giving, receiving, or soliciting, directly or indirectly, anything of value to improperly influence actions, including bribes or facilitation payments.
    - Example: accepting a kickback from a vendor in exchange for steering a contract award.
  - Collusion
    - Definition: An arrangement between two or more individuals designed to achieve an improper purpose.
    - Example: submitting inflated expense reports collectively after a mission.
  - Coercion
    - Definition: Impairing, harming, or threatening to impair or harm any person or their interests to improperly influence actions.
    - Example: threatening a recruitment panel member with a negative performance review to secure a recommendation.
  - Obstruction
    - Definition: Deliberately destroying, falsifying, altering or concealing evidence, making false statements, or acts intended to impede OII inquiries or the Fund’s contractual rights of audit or access to information.
    - Example: refusing to attend interviews and destroying expense claim copies when OII requests records.
  - Conflict of Interest
    - Definition: Personal or outside interests interfering, or appearing to interfere, with the performance of official duties and required impartiality.
    - Example: arranging mission accommodation at a hotel owned by a family member without disclosure.
- The examples are not exhaustive.

### Prevention, Policies, and Responsibilities
- Reporting and cooperation
  - All Fund personnel must promptly report good faith allegations that a Prohibited Activity may have occurred to OII.
  - Fund personnel must cooperate in OII preliminary inquiries and investigations; cooperation is strictly confidential.
- Obligations of Fund personnel (general)
  - Act with honesty and integrity; avoid engaging in Prohibited Activities.
  - Prohibited Activities by Fund personnel are misconduct and may result in disciplinary measures ranging from written warnings to termination of employment with a bar on rehire.
  - The Fund may seek recovery of losses sustained due to Prohibited Activities.
  - Prohibited Activities outside Fund duties may also be grounds for disciplinary action.
  - Personnel must monitor for and take proactive measures against risks of Prohibited Activities.
  - Personnel should seek advice from the Ethics Advisor when unsure of obligations.
  - Complete all mandatory training programs relating to prevention of Prohibited Activities.
  - As part of the Annual Ethical Conduct and Core Values Certification, personnel must confirm they have read and comply with this policy.
- Heightened responsibilities
  - Managers, supervisors, and personnel involved in recruitment and procurement must:
    - supervise performance, methods, and output to ensure ethical conduct;
    - promote awareness of this policy and take proactive steps to prevent and identify potential Prohibited Activities;
    - seek guidance from the Ethics Advisor as needed; and
    - may request training and outreach from the Ethics Advisor for their teams.
  - Vendor management and procurement personnel must ensure contractual documents with Third-Parties incorporate obligations under this policy, including the supplier code of conduct.
- Internal controls and risk management
  - All Fund Departments and Offices are responsible for implementing internal controls—proper separation of duties, systems access controls, multi-layered approval requirements, monitoring, and other accountability measures consistent with industry risk mitigation standards.
  - Departments and Offices are the “First Line” business process owners to design and execute controls to manage fraud and corruption risks.
  - Departments and Offices must report identified instances of Prohibited Activities in a timely fashion as part of the institutional risk event reporting framework established by ORM.

### Third-Party Responsibilities
- Third-Parties, their employees, personnel, and agents must:
  - interact honestly and with integrity;
  - abide by the highest ethical, legal, and moral standards in dealings with the Fund;
  - not engage or attempt to engage in Prohibited Activities.
- Consequences for Third-Party Prohibited Activities:
  - suspension or termination of relationship with the Fund;
  - disqualification from further engagements with the Fund;
  - potential actions to recover losses sustained by the Fund.
- Third-Party responsibilities are set out in the Fund Supplier Code of Conduct.

### Reporting Mechanisms and Confidentiality
- Reporting options for suspected Prohibited Activities (anonymous or confidential):
  - Telephone: toll-free number 1-800-548-5384 available within North America on a 24/7 basis.
  - Online: at www.IMF.org/integrityhotlinereporting.
  - OII may be contacted directly by:
    - E-mail: investigations@imf.org
    - Letter (postal address provided for OII).
- Confidentiality:
  - Reports of allegations and OII investigations are strictly confidential.
  - Information is disclosed only to staff with a strict need to know.
  - Investigation reports are strictly confidential internal Fund documents.

### Protection Against Retaliation and Referrals
- Protection:
  - Fund personnel who report allegations or cooperate in investigations are protected from retaliation under the Fund’s Retaliation Policy.
  - Personnel subject to or cooperating with an investigation may seek confidential support from the Office of the Ombudsperson.
- Referral to national authorities:
  - Management may, at its discretion, refer allegations of Prohibited Activities to appropriate authorities of a member country.

### Administration, Periodic Review, and Recovery
- Periodic review:
  - The policy and implementation measures will be reviewed periodically and updated as deemed necessary in the interests of the Fund.
- Administrative responsibilities:
  - Director, Human Resources Department (HRD): responsible for administration pertaining to Fund personnel and requested to keep the policy under review.
  - Director, Corporate Services and Facilities Department (CSF): responsible for administration pertaining to Third-Parties.
  - Office of Internal Investigations (OII): sole office mandated to receive reports and conduct preliminary inquiries and investigations.
  - Ethics Office (ETO): responsible for providing advice and guidance to staff, undertaking outreach and training on prevention, and recommending improvements to HRD.
  - Finance Department (FIN): responsible for taking reasonable steps to recover amounts due under the policy, in collaboration with OII as applicable.

### Table of Contents — Policy Sections
- The Policy is divided into the following sections:
  1. Purpose
  2. Scope and Application
  3. Definitions and Examples
  4. Policies and Procedures for the Prevention of Prohibited Activities
  5. Responsibility
  6. Reporting Prohibited Activities
  7. Periodic Review and Updates
  8. Administration
  9. List of Resources

### Key contact details and references (as provided)
- Integrity Hotline telephone (North America, toll-free, 24/7): 1-800-548-5384
- Integrity Hotline online reporting: www.IMF.org/integrityhotlinereporting
- OII e-mail: investigations@imf.org
- OII postal address: Office of Internal Investigations, International Monetary Fund, 1900 Pennsylvania Avenue NW, Room No. HQ2-3A-312, Washington, DC 20431

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_Source: https://www.imf.org/-/media/files/about/ethics/policy/anti-fraud-anti-corruption-011725.pdf_