CODE OF CONDUCT FOR STAFF AND VOLUNTEERS

African Center for Governance, Asset Recovery, and Sustainable Development Ltd/GTE

Code of Conduct for Staff and Volunteers

April 2025

Acronyms

AC	African Center for Governance, Asset Recovery and Sustainable Development
ED	Executive Director
HR	Human Resource
IT	Information Technology

Introduction

This Code of Conduct outlines the standards of behavior expected of all staff and volunteers at the African Center for Governance, Asset Recovery, and Sustainable Development (the African Center). It outlines the principles and standards of behavior expected of all staff and volunteers and sets clear guidelines to prevent fraud, bribery, and corruption, manage conflicts of interest, and regulate the acceptance of gifts and hospitality. As representatives of the African Center, all individuals are expected to uphold the highest standards of integrity, transparency, and ethical conduct in their work.

Purpose

The purpose of this Code of Conduct is to:

Ensure that all activities are conducted with integrity and accountability.
Protect the reputation and integrity of the African Center.
Ensure a safe, inclusive, and productive environment for all staff, volunteers, and stakeholders.
Prevent fraud, bribery, and corruption within the African Center.
Manage conflicts of interest to protect the African Center’s integrity.
Establish clear guidelines on the acceptance of gifts and hospitality.
Promote a culture of transparency and ethical behavior in all dealings.

Scope

This Code of Conduct applies to all staff, volunteers, board members, contractors, and any other individuals acting on behalf of The African Center. It covers all organizational activities, including interactions with beneficiaries, partners, suppliers, and other stakeholders.

African Center’s Mission and Vision

Vision

We envision a world free from illicit financial flows, where proceeds of crime are recovered and returned to the victims of corruption to improve livelihoods and reduce poverty and inequality.

Mission

Our mission is to reinforce the links between governance, asset recovery, and sustainable development goals in line with Agenda 2030 and the promotion of the rule of law, strengthening justice institutions, preventing illicit financial flows, recovering stolen assets, and social reuse of stolen assets.

Core Principles

Uphold the Integrity and Reputation of African Center

African Center staff shall treat all people fairly with respect and dignity.
When working in an international context or travelling internationally on behalf of the African Center, such staff must be observant of all local laws and be sensitive to local customs.
African Center staff must seek to ensure that his/her conduct does not bring African Center into disrepute and does not impact on or undermine his/her ability to undertake the role for which he/she is employed.
African Center staff must not work under the influence of alcohol or use, or be in possession of, illegal substances on African Center premises or accommodation.

Refrain from Abusive or Exploitative Conduct

Africa Center staff must not engage in sexual activity with children (persons under the age of 18). Mistaken belief in the age of a child is not a defence.
African Center staff must not indulge in the exchange of money, employment, goods, or services for sex, including sexual favours or other forms of humiliating, degrading or exploitative behaviour. This includes any exchange of assistance due to the beneficiaries of assistance.
African Center staff must not engage in sexual relationships with beneficiaries of assistance, since they are based on inherently unequal power dynamics.
African Center staff must not engage in any commercially exploitative activities with children or vulnerable adults, including child labour or trafficking.
African Center staff must not physically assault a child or vulnerable adult.
African Center staff must not emotionally or psychologically abuse a child or vulnerable adult.

Safety, Health, and Welfare of All African Center Staff

African Center staff must adhere to all legal and organizational health and safety requirements in force at the location of work.
African Center staff must comply with any local security guidelines and be proactive, informing management of any necessary changes to such guidelines.
African Center staff must behave in a manner such as to avoid any unnecessary risk to the safety, health, and welfare of themselves and others, including partner organisations and communities with whom we work.

Use of Information, Assets, and Resources

African Center staff must ensure that the use of African Center assets and resources entrusted in his/her care is taken care of in a responsible manner and must account for all money and property in his/her possession.
African Center staff must not use African Center’s IT equipment, software, or e-mail and social media platforms to engage in activity that is illegal under local or international law or that encourages conduct that would constitute a criminal offence. This includes any material that intimidates or harasses any group based on protected characteristics or encourages extremism.
African Center staff must not use African Center’s IT equipment to view, download, create, distribute, or save in any format inappropriate or abusive material, including but not limited to pornography or depictions of child abuse.

Uphold Confidentiality

African Center staff must exercise due care in all matters of official business and not divulge any confidential information relating to colleagues, work-related matters, or any sensitive information unless legally required to do so.
African Center Staff are not allowed to disclose any classified or proprietary information to anybody without authorization. Staff who have access to or are in control of such information should always provide adequate safeguards to prevent its abuse or misuse. Examples of misuse include disclosure of information in return for monetary rewards or use of information for personal interest.

Fraud, Bribery, and Corruption

The African Center has a zero-tolerance policy towards fraud, bribery, and corruption. All staff and volunteers must always act honestly and with integrity, safeguarding the African Center’s resources and reputation.

Definitions

Fraud: Any act of deception intended for personal gain or to cause loss to another party. This includes falsifying records, misappropriating funds, or manipulating data.
Bribery: Offering, giving, receiving, or soliciting anything of value to influence the actions of another person in a position of power or authority.
Corruption: The abuse of entrusted power for private gain, including activities such as embezzlement, nepotism, or favoritism.

Reporting

African Center staff are obligated to bring to the attention of the relevant manager any potential incident, abuse, or concern that they witness, are made aware of, or suspect that appears to breach the Standards contained in this Code. African Center staff reporting concerns are protected by the Disclosure of Malpractice in the Workplace policy.
Staff members who have a complaint or concern relating to a breach of the Code should report it immediately to their line manager. If the staff member does not feel comfortable reporting to their line manager (for example, if they feel that the report will not be taken seriously, or if that person is implicated in the concern), they may report to any other appropriate staff member. For example, this could be a senior manager or a member of the HR Team.
Staff members receiving reports or concerns are obliged to take action or refer the report immediately as per the African Center Complaints Policy and procedures.
Any suspected fraud, bribery, or corruption must be reported immediately to the Executive Director, HR, or the designated compliance officer. All reports will be investigated thoroughly and confidentially.

Consequences

Individuals found to be involved in fraud, bribery, or corruption will face disciplinary action, including termination of employment or volunteer agreement, and may be subject to legal action.

Conflict of Interest

A conflict-of-interest situation arises when the “private interests” of the staff compete or conflict with the interests of the organisation. “Private interests” means both the financial and personal interests of the staff or those of their connections, including:

family and other relations;
personal friends;
the clubs and societies to which they belong; and
any person to whom they owe a favour or are obligated in any way.

African Center staff should avoid using their official position or any information made available to them in the course of their duties to benefit themselves, their relations, or any other persons with whom they have personal or social ties. Staff must avoid putting themselves in a position that may lead to an actual or perceived conflict of interest with the organisation. Failure to avoid or declare any conflict of interest may give rise to criticism of favoritism, abuse of authority, or even allegations of corruption. Staff involved in the procurement process should declare a conflict of interest if they are closely related to or have a beneficial interest in any company that is being considered for selection.

When called upon to deal with matters of the organisation for which there is an actual or perceived conflict of interest, the staff member should make a declaration in writing to his supervisor. He should then abstain from dealing with the matter in question or follow the instructions of his supervisor, who may reassign the task to other staff.

Upon disclosure, the African Center’s ED and the Board will assess the situation and determine the appropriate course of action, which may include recusal from decision-making, reassignment of duties, or other measures to mitigate the conflict.

Gifts and Hospitality

Staff and volunteers must not accept gifts, hospitality, or other benefits that could influence, or appear to influence, their decision-making or actions on behalf of the African Center. However, modest gifts, such as promotional items or tokens of appreciation with a nominal value of less than N50,000, may be accepted, provided they do not create an obligation or perceived obligation. Meals or hospitality offered as part of official duties (e.g., working lunches, conference receptions) may be accepted, provided they are of modest value and are not excessive.

Other Gifts

For gifts which are presented to staff in their official capacity and of value (above N200,000), the refusal of which could be seen as unsociable or impolite (e.g. a car presented to a staff member during a seminar in which he is invited to be the guest speaker), the Management Board has given a blanket permission for the staff to accept these gifts. In such circumstances, the African Center will promptly contact the giver of the gift to appreciate him/her officially. In addition, such a gift will be published in a newspaper showing the name of the applicant, the occasion of the offer, the nature and estimated value of the gift, and for what purposes the gift will be used for the African Center.

Disclosure and Approval

All gifts and hospitality must be disclosed to the designated compliance officer. Any gifts or hospitality that could be perceived as influencing the recipient’s actions must be declined or, if accepted, reported and discussed with management.

Returning Gifts

If a gift is received that violates this policy, it should be politely declined and returned with an explanation of the African Center’s policy. If returning the gift is not possible or would cause offense, the gift should be reported and handed over to management.

African Center’s Property

Staff given access to any property of the African Center should ensure that it is properly used for the purpose of conducting the organization’s business. Misappropriation of the organization’s property for personal use or resale is strictly prohibited.

Compliance and Enforcement

Acknowledgment: All staff and volunteers must acknowledge that they have read, understood, and agree to abide by this Code of Conduct. This acknowledgment will be documented and kept on file.

Training: Regular training will be provided to ensure all individuals are aware of their responsibilities under this Code of Conduct.

Monitoring: The African Center will regularly monitor compliance with this Code of Conduct and take necessary steps to enforce its provisions.

Consequences of Violation: Any breach of this Code of Conduct may result in disciplinary action, including termination of employment or volunteer agreement, legal action, or other measures deemed appropriate by the African Center.

In accepting my appointment, I undertake to discharge my duties and to regulate my conduct by the requirements of this Code.