Anti-Fraud, Bribery and Corruption Policy

"bee Charity" Verein (“BeeCharity”, “we”, “us”, “our”) is a Swiss association (Verein) with its seat in Dübendorf, Canton of Zurich, registered in the Commercial Register Office of the Canton of Zurich under UID CHE-457.076.818. As a charity that exists on the trust of its donors and the goodwill of its volunteers and partners, we are committed to the highest standards of honesty, integrity, openness and accountability, and we have zero tolerance towards fraud, bribery and corruption in any form.

The purpose of this Anti-Fraud, Bribery and Corruption Policy is to set out clearly how BeeCharity identifies, prevents, detects and responds to fraud, bribery and corruption, whether committed by a board member, volunteer, contractor, partner or any third party. It explains the controls we rely on to protect charitable funds and assets, the responsibilities that everyone connected with us carries, and the action we will take when something goes wrong.

We recognise that, as a small and still-developing organisation, our resources are limited; but we do not regard integrity as something to be scaled up later. The controls described here are proportionate to our size and are designed to grow with us. This document has been formally adopted by the board and is published in the spirit of transparency; it describes the standards we hold ourselves to. Throughout, our joint signing authority — under which any binding commitment requires two authorised representatives acting together — operates as a central safeguard against financial wrongdoing.

For the purposes of this policy, we use broad, plain-language definitions so that no one is in doubt about the conduct we are seeking to prevent. “Fraud” means dishonestly obtaining a benefit, or causing a loss, by deception or abuse of position. It includes, in particular:

Fraud may be committed against BeeCharity (for example by a volunteer, supplier or external fraudster) or in the name of BeeCharity to the detriment of others (for example a bogus appeal using our identity). Both are covered by this policy. Fraud can also be internal or external, deliberate or reckless; what unites the conduct we prohibit is dishonesty coupled with an intention to gain or to cause loss.

• False representation — dishonestly making a statement or giving an impression that is untrue or misleading in order to make a gain or cause a loss, such as submitting a false invoice or expense claim.
• Failing to disclose information — dishonestly failing to disclose information that there is a legal or moral duty to disclose, in order to make a gain or cause a loss.
• Abuse of position — dishonestly abusing a position of trust in which a person is expected to safeguard the association’s interests, in order to benefit oneself or another.
• Misappropriation — the theft, diversion or misuse of the association’s money, donations, grants, property or other assets.
• Financial irregularity — the falsification, concealment or destruction of records, accounts or documents to disguise any of the above.

Bribery and corruption are distinct from, but often connected to, fraud, and BeeCharity prohibits them absolutely. For the purposes of this policy:

A bribe does not have to involve money — it can be a gift, hospitality, a favour, an offer of employment, a donation solicited on improper terms, or any other advantage. It is irrelevant whether the advantage is given or received directly or through a third party, and whether it takes place in Switzerland or abroad; Swiss law penalises the bribery of both public officials and private individuals, and we hold ourselves to that standard everywhere we operate. Offering or accepting a bribe is never acceptable, regardless of local custom or the perceived benefit to the association, and no one will ever suffer for refusing to pay or accept a bribe, even if it results in BeeCharity losing an opportunity.

• “Bribery” means offering, promising, giving, requesting, agreeing to receive or accepting any financial or other advantage as an inducement or reward for improperly performing a function or activity, or to influence a decision.
• “Corruption” means the misuse of entrusted power, office or position for private gain, whether that gain is for the individual concerned or for a connected person or organisation.
• “Facilitation payment” means a small payment made to secure or speed up a routine action to which one is already entitled; such payments are a form of bribery and are prohibited.
• “Kickback” means the return of a sum already paid, or to be paid, as a reward for awarding or favouring a person in business dealings.

Preventing fraud, bribery and corruption is a shared responsibility, and everyone connected with BeeCharity — every board member, volunteer, contractor, partner and representative — is expected to act honestly, to comply with this policy, and to report any suspicion of wrongdoing promptly. Integrity is not the job of one person; it is a collective duty owed to our donors and beneficiaries.

Within that shared responsibility, specific roles apply. The board of BeeCharity — currently the Chairperson of the Board and the Member of the Board and Treasurer — holds ultimate responsibility for this policy and for the culture of honesty that underpins it. The Treasurer leads on the day-to-day financial controls that give the policy practical effect. Because BeeCharity currently has a two-member board, we are especially conscious that concentration of control is itself a risk: our joint signing authority directly addresses this by ensuring that neither board member can act alone on any binding financial matter, and we supplement it with external checks — such as bank records and, in time, independent review — so that oversight does not rest on trust alone.

• The board approves this policy, promotes a zero-tolerance culture, oversees its effectiveness, and receives and acts on reports of serious incidents.
• The Treasurer maintains the financial controls, monitors transactions, ensures records are kept, and coordinates the response to concerns.
• Board members lead by example, comply personally with every control (including joint signing authority), and never place themselves above the rules.
• Volunteers, contractors and partners must comply with this policy, avoid any conduct that could amount to fraud, bribery or corruption, and report concerns without delay.

Fraud, bribery and corruption can take many forms, and describing them helps everyone recognise warning signs. Examples of the conduct this policy is designed to prevent include, but are not limited to:

This list is illustrative, not exhaustive. Any dishonest act intended to gain an advantage or cause a loss to BeeCharity, its donors or its beneficiaries falls within this policy, whatever form it takes and however small it may appear.

• Misappropriating, diverting or “borrowing” donations, grant funds or cash collected at events.
• Submitting false, inflated or duplicated expense claims, invoices or reimbursement requests.
• Creating fictitious suppliers, beneficiaries or volunteers in order to extract payments.
• Falsifying, altering or destroying receipts, records, accounts or financial reports.
• Offering, giving, requesting or accepting kickbacks, bribes, or gifts and hospitality intended to influence a decision.
• Awarding contracts or grants to friends, relatives, or connected parties on improper or non-competitive terms.
• Using the association’s bank accounts, property, equipment, information or name for personal benefit or unauthorised purposes.
• Misrepresenting how funds have been or will be used, including in appeals or reports to donors and funders.
• Colluding with a supplier, partner or third party to defraud the association or a donor.

Strong financial controls are our first line of defence against fraud, because they reduce the opportunity for wrongdoing and increase the likelihood that anything improper is detected quickly. Our controls are proportionate to our current size and activities, are documented, and are strengthened as the organisation grows and as transaction volumes increase.

The Treasurer is responsible for maintaining these controls under the oversight of the board, and every person who handles money or authorises expenditure on behalf of BeeCharity must operate within them. Attempting to bypass a control is itself a breach of this policy, regardless of intention.

• Segregation of duties, so that no single individual controls a transaction from initiation to completion.
• Documented approval for all expenditure, supported by genuine invoices, receipts or other evidence.
• Regular reconciliation of bank statements against donation and expenditure records.
• Restricted and individually attributable access to bank accounts, payment systems and sensitive financial information.
• Preference for traceable payment methods and strict limits on the handling of cash.
• Prompt banking and recording of all income, including donations received online, by transfer, or in person.
• Periodic review of financial records by the board, and, as resources allow, independent examination of the accounts.

"bee Charity" Verein operates under joint signing authority (collective signature by two). This means that any legally binding commitment, payment instruction, contract or material financial decision must be approved and signed by two authorised representatives acting together. No single person — including either member of the board — can move the association’s funds, enter a contract, or otherwise bind BeeCharity alone.

Dual authorisation is the cornerstone of our anti-fraud framework. By requiring two authorised representatives to act jointly, it ensures that every significant transaction is seen and approved by more than one person, dramatically reducing the risk that funds can be misappropriated, that a fraudulent payment can be made, or that the association can be committed to an improper arrangement without scrutiny.

This control applies to the opening and operation of bank accounts, the making of payments above routine thresholds, the signing of contracts and grant agreements, and the acceptance or return of significant donations. Because our board currently has only two members, both must exercise particular diligence: each acts as a check on the other, and neither should ever sign a document or approve a payment they do not fully understand or that lacks proper supporting evidence. As the board grows, dual authorisation will continue to apply, drawing on a wider pool of authorised representatives.

Undeclared conflicts of interest are a common route to fraud and corruption, because they allow private interests to influence decisions that should be taken solely in the charity’s interest. Everyone involved in a BeeCharity decision must declare any personal, financial, professional or family interest that could influence, or could reasonably be perceived to influence, their judgement.

Interests are declared and recorded, and conflicts are managed, in accordance with our Conflicts of Interest Policy. Anyone with a material conflict withdraws from the relevant discussion and decision, and must never use their position to secure a benefit for themselves or a connected person. This is especially important in procurement and in the acceptance of gifts and donations, where the risk of improper influence is highest.

Because a conflict affecting one member of a two-person board cannot be resolved simply by the other member deciding alone under joint signing authority, such matters are handled with particular care — by deferring the decision, referring it to the wider membership, or seeking independent advice, as set out in our Conflicts of Interest Policy. In this way, conflicts management and anti-fraud controls reinforce one another.

The purchase of goods and services, and the engagement of suppliers, contractors and partners, is an area of heightened fraud and corruption risk, and we apply specific controls to it. Procurement decisions are made on the basis of value for the charity — considering quality, cost, reliability and fit with our mission — and never to favour a connected person or in return for any personal advantage.

For significant purchases we seek to compare options objectively, to obtain more than one quotation where practical, and to document the reasons for our choice so that the decision can be shown to have been made fairly. Anyone with an interest in a prospective supplier must declare it and take no part in the selection or approval of that supplier. Contracts with connected parties are avoided where possible and, where genuinely justified, are transparently declared, decided without the conflicted person, and entered into on arm’s-length terms.

Suppliers and partners are expected to meet appropriate standards of integrity, and, as part of our Partner Due Diligence Policy, we take reasonable steps to satisfy ourselves that those we work with do not engage in fraud, bribery or corruption. All procurement commitments are subject to our joint signing authority, so that two authorised representatives approve any contract that binds the association, and to the financial controls and record-keeping requirements described elsewhere in this policy.

BeeCharity’s assets — including donated funds, bank balances, equipment, digital accounts, intellectual property and the association’s name and reputation — are held on trust for our charitable purpose, and protecting them from theft, misuse and loss is a core aim of this policy. Assets may only ever be used for legitimate charitable purposes properly authorised by the association.

We protect financial assets through the banking, segregation-of-duties and dual-authorisation controls described above, keeping funds in accounts in the name of the association and limiting and attributing access to them. Physical assets are recorded and safeguarded, and are not used for private purposes. Digital assets — including our website, email, social-media and payment-platform accounts — are protected with appropriate access controls, strong and non-shared credentials, and prompt removal of access when a person’s involvement ends.

Our name and reputation are themselves valuable assets, and we guard against their misuse — for example bogus appeals or unauthorised fundraising purporting to act for BeeCharity. We monitor for such misuse, make clear how genuine donations are collected, and will report fraudulent use of our identity to the relevant authorities and payment providers. Anyone entrusted with a BeeCharity asset is personally responsible for using it only as authorised and for returning it when asked or when their involvement ends.

All reports and suspicions of fraud, bribery or corruption are taken seriously and assessed promptly by the board or, where the Treasurer is best placed, under the Treasurer’s coordination — save that no one investigates a matter in which they are personally implicated or conflicted. Where an initial assessment indicates that a concern may have substance, a proportionate and impartial investigation is carried out.

Investigations are conducted fairly, objectively and confidentially. We take immediate steps to preserve evidence and, where necessary, to prevent further loss — for example by suspending a payment, restricting access to an account, or temporarily standing a person back from a role while the matter is examined. Suspension of this kind is a neutral, precautionary measure and is not a finding of guilt. Anyone whose conduct is questioned is treated fairly and given a proper opportunity to respond before any conclusion is reached.

Given the size of our organisation, we will not hesitate to involve external professionals — such as accountants, lawyers or forensic specialists — where the nature, complexity or seriousness of a matter requires it, and to notify our bank or payment providers where funds are at risk. Where an investigation suggests that a criminal offence may have been committed, we will report the matter to the police or other competent Swiss authorities and cooperate fully with them.

We want anyone who has a genuine concern about fraud, bribery or corruption to feel able to speak up, and we are committed to protecting those who do. A person who reports a concern in good faith — that is, with an honest belief that it is or may be true — will not suffer any detriment, victimisation or disadvantage as a result, even if the concern later turns out to be mistaken or unfounded.

Reports are handled as confidentially as possible, and we will not disclose the identity of a person who raises a concern without their consent unless we are required to do so by law or it is unavoidable in order to investigate the matter properly, in which case we will discuss it with them first wherever we can. We also accept anonymous reports and will act on them so far as the information provided allows.

This protection sits alongside our separate Whistleblowing Policy, which sets out in more detail how serious concerns can be raised and escalated. Deliberately making a false or malicious allegation, however, is itself a serious matter and may be dealt with under the relevant policy. Anyone who retaliates against a person for raising a genuine concern will be subject to the sanctions described below.

If you suspect fraud, bribery or corruption — however uncertain you are — please report it as soon as possible. You do not need to have proof, you should not attempt to investigate the matter yourself or confront anyone, and you should avoid alerting a suspected wrongdoer, as this could allow evidence to be destroyed or funds to be moved.

Concerns can be raised with the Treasurer or the board at beecharity1@gmail.com, or through the confidential channels described in our Whistleblowing and Complaints policies. If you believe that funds or assets are at immediate risk, please say so clearly and prominently so that we can act quickly to protect them. Where a concern involves a member of the board, it can be directed to the other board member or raised through the wider membership, so that it is never considered only by the person it concerns.

When reporting, it helps to include as much relevant detail as you can — what you saw or suspect, who was involved, when it happened, and any supporting information — but you should never put yourself at risk or delay reporting in order to gather more. We will acknowledge concerns, keep the person who raised them informed so far as confidentiality allows, and treat every genuine report with the seriousness it deserves.

Fraud, bribery and corruption are treated as extremely serious breaches of the trust placed in us, and we respond firmly when they are established. Anyone found to have engaged in such conduct may have their involvement with BeeCharity ended — whether as a board member, volunteer, contractor or partner — and may be excluded from any future involvement with the association.

Where a board member is involved, the matter will be dealt with under our governance arrangements and, where appropriate, referred to the general meeting of members. Contracts with suppliers or partners found to have acted corruptly will be terminated, and we will decline to work with them again. In every case, decisions that formally commit the association in response — including terminating a contract or pursuing recovery — are taken under our joint signing authority.

Where we believe the law has been broken, we will refer the matter to the police or other competent Swiss authorities and will cooperate fully with any resulting investigation or proceedings. We will also take reasonable steps to recover misappropriated funds or assets, including through civil action where justified and proportionate. Retaliation against someone who has reported a genuine concern is itself a breach of this policy and will be dealt with in the same serious way.

Accurate and complete records are essential both to preventing fraud and to demonstrating that we have handled charitable funds properly. We keep clear records of financial transactions, approvals and authorisations, declarations of interest, gifts and hospitality, and any reports, concerns or investigations relating to this policy.

These records are stored securely, with access restricted to those who need it, and any personal data they contain is processed and retained in accordance with our Privacy Policy and Data Retention Policy and applicable Swiss law, including the revised Federal Act on Data Protection (revDSG). Records relating to a suspected or actual incident are retained for as long as is necessary for the investigation, any resulting action, and our legal and governance obligations.

Good record keeping allows the board to monitor the effectiveness of our controls, enables any transaction to be traced and explained, and provides the evidence needed if a concern has to be investigated or reported. It also supports the transparency we owe to our donors and to the due-diligence and validation partners who assess our governance.

This policy was formally adopted by the board and is reviewed at least annually, or sooner if there is a relevant change in Swiss law, in recognised good practice on fraud and bribery prevention, in the requirements of the funders and validation programmes we rely on, or in the nature, scale or complexity of our activities and finances.

As BeeCharity grows — for example if the board expands beyond two members, if transaction volumes increase, or if we take on employees — we will strengthen the controls described here accordingly, and this policy will be updated to reflect that. Any material change to the policy is approved under our joint signing authority, with two authorised representatives acting together. The version and status shown at the top of this page reflect its current standing as a policy formally adopted by the board, and we will update the version history when it is adopted or amended.

If you have any question about this policy, or if you wish to report a suspicion of fraud, bribery or corruption, please contact us. Every genuine concern is treated seriously, fairly and as confidentially as possible.

Fraud and integrity concerns: beecharity1@gmail.com

General enquiries: beecharity1@gmail.com

Postal address: "bee Charity" Verein, c/o Jasmin Semra Gabrielli, Bahnhofstrasse 33, 8600 Dübendorf, Switzerland (please mark correspondence “Confidential — for the attention of the Board”)