SEWA is committed to the setting up, utmost standards for transparency and accountability in all its
affairs. SEWA strives in attaining it’s mission through compliance of high legal and ethical
SEWA does not tolerate any form of bribery, embezzlements or corruption, and will uphold all laws
countering bribery, fraud and corruption in all forms.
The purpose of this policy is to set out the responsibilities of SEWA and those individuals acting
its behalf in observing and upholding SEWA’s position on bribery and corruption. Every individual or
group of individuals, associated to SEWA in any form, whether the staff members, the ad-hoc staff
engaged in the program activities of the organization, the consultants, the contractors, the
the partner organisations and any other party with a financial or trustee-beneficiary relationship
SEWA are expected to share this commitment. The basic objective of this statement is setting out the
policy of SEWA towards the prevention and identification of bribery and corruption and the certain
procedures to be followed, if at all, any fraud is found or having an idea / impression of it’s
This policy applies to the Staffs, ad-hoc staffs, Advisers, Consultants, Suppliers, Partners and
Individuals acting on behalf of the Society, irrespective of their location. Governing Body (GB) has
been excluded from the scope, considering the fact that GB is not directly involved in any of SEWA’s
day-to-day business and/or routine functions. The Governing Body has vested powers and
to various functionaries and constituted committees to execute routine functions of the
SEWA will not engage in bribery or any form of unethical inducement or payment including
facilitation payments and "kickbacks." All the Staff, Ad-hoc staff, Advisers, Consultants,
Suppliers, Partners and Individuals acting on behalf of the SEWA are required to avoid any
activities that might lead to, or suggest, a conflict of interest with the activities of SEWA.
SEWA expects its suppliers and partners to act with integrity and without thought or actions
involving bribery and/or corruption and will, where appropriate, include clauses to this effect
It is prohibited, directly or indirectly, for any staff or individual acting on behalf of SEWA
offer, give, request or accept any bribe (i.e. gifts with mala-fide intentions, loan, payment,
reward or advantage, either in cash or any other form of inducement), to or from any person or
company in order to gain commercial, contractual or regulatory advantage for SEWA, or in order
gain any personal advantage for an individual or anyone connected with the individual in a way
This policy requires employees and individuals acting on behalf of SEWA:
Not to offer, promise or make any bribe or unauthorised payment or inducement of any kind to
Not to solicit business by offering, promising or making any bribe or unofficial payment to
Not to request or accept any kind of bribe or unusual payment or inducement that would not
be authorised by SEWA in the ordinary course of business;
To refuse any bribe or unusual payment and to do so in a manner that is not open to
misunderstanding or giving rise to false expectation; and to report any such offers;
Not to make facilitation payments. These are payments used by businesses or individuals to
secure or expedite the performance of a routine or necessary action to which the payer of the
facilitation payment has a legal or other entitlement. SEWA will not tolerate or condone such
payments being made;
To report any breaches of this policy's principles or standards or of any associated;
Criminal Offence (as defined in IPC)
- It is a criminal offence to:
- Offer a bribe;
- Accept a bribe;
- Fail to prevent a bribe (only applies to commercial organisations);
Staffs, ad-hoc staff, advisers, consultants, suppliers, partners and any individuals acting on
behalf of SEWA should be made aware that if they are found guilty by a court of committing
bribery, embezzlement or fraudulence an individual could face prosecution as per the norms of
IPC (Indian Penal Code).
Gifts and Hospitality:
SEWA realises that giving and receiving of gifts and hospitality without any mala-fide intentions,
in other words, where nothing is expected in return helps form positive relationships with third
parties where it is proportionate and properly recorded. This does not constitute bribery and
consequently such actions are not considered a breach of this policy.
Raising a Concern:
If an employee or an individual acting on behalf of SEWA is offered a bribe, or a bribe is
solicited from them, they should not agree to it unless their immediate safety is in jeopardy.
Should this be the case, the employee or individual should at first instance contact the
Unit/Centre In-Charge as soon as they are able to do so. The employee or individual may be
required to give a written account of the events to assist with any investigation. If any
Unit/Centre In-Charge is involved in such an act, the individual may contact Executive Officer
for reporting the case and likewise if the concerned Executive Officer is involved in such an
act, the individual may directly contact the Chairman of SEWA for reporting such case.
Employees or individuals acting on behalf of SEWA are encouraged to raise concerns about any
instance of bribery or corruption at the earliest possible stage. The employee or individual
raising a concern can do so in confidence and without fear of reprisals. All reports raised are
taken seriously and, where appropriate, investigated. No employee or individual will be
discriminated against in any way as a result of reporting a concern in good faith.
If any instance of bribery or corruption is identified; SEWA management will take the remedial
steps immediately. SEWA has it’s own system of investigating it’s staff member for violation of
service conduct including financial irregularities, corruption, fraud or embezzlement. If the
charges are proved the delinquent may be awarded penalties depending on the gravity of
These rules are based on the following principles:
The right of SEWA to take appropriate disciplinary steps against any delinquent staff
member, who acts in a manner conflicting with the code of conduct and prescribed rules /
At the same time the rules also recognize the right of delinquent staff member to a fair hearing
and applicable and just disciplinary action.
The emphasis of disciplinary action is on prevention, justice and rehabilitation.
Review of this Policy:
In the interests of maintaining best practice, the contents of this Anti-Fraud Policy will be
by the Audit and Executive Council every three years.
Reporting and Investigation:
An individual can report at three levels, as indicated below:
- Centre in-charge (CiC) / Executive Officer (EO) at primary level.
- Chairman at secondary level, in case if the concerned Executive Officer (EO) and/or
Centre in-charge is/are involved in such an act.
- Executive Council (EC) will form a committee to investigate.
- Governing Body will have the discretion to form a committee to investigate, in such a
case where any member(s) of the Executive Council is involved in the act.