CODE OF ETHICS AND PROFESSIONAL CONDUCT – v.2024/05/17
1. Introduction
This Code of Ethics and Professional Conduct applies to everyone working for IBF’s group of companies (the “IBF staff”), regardless of the nature of their relationship (employee, self-employed, …).
This Code is an integral part of all contracts governing a working relation with IBF’s group of companies (“IBF”). The Code is not static by nature, but on the contrary will be subject to regular evaluation and training. The IBF staff are expected to refresh their awareness of this Code, and will be required to expressly re-confirm their adherence to the Code on a regular basis.
The Code is an important tool for the commitment of IBF to conduct business in accordance with not only the applicable legal requirements, but also with high standards of business ethics.
This Code of Ethics and Professional Conduct identifies situations of potential ethical risks that can be encountered by IBF staff and it provides guidance and information helping to recognize and to deal with such ethical issues. On the other hand, it is impossible to foresee every possible situation that could lead to ethical risks ; in these cases, two governing principles apply : IBF staff must act in good judgment and inform or report others.
As an overall principle, IBF staff should always feel free, without any fear for negative consequences, to raise any issue related to ethical questions they encounter in their work. If you are concerned by what appears to be an ethical problem : speak out. Any person who receives any confidential information is required to report this to at least two Code of Ethics and Professional Conduct’s Contact Persons (including at least Mr Antonio Barbero – Independent Director responsible for Ethics – antonio.barbero@polito.it) and to the external Ethical Compliance Counsel (Mr. Michael Verhaeghe – ecc@ibf.be).
Any IBF staff who violates or knowingly participates in the violation of this Code by others, will be subject to sanctions, in accordance with the applicable laws.
Our actions must consistently demonstrate that we fairly and honestly deal with our colleagues, clients, collaborators, vendors, and beneficiaries. This ethical standard is essential to the implementation of successful development projects, as well as demonstrating to clients that we can be trusted to do the right thing when managing their resources and to beneficiaries that we are a trustworthy and reliable partner.
2. Our Mission, Vision and Values
IBF’s mission is to provide international funding agencies and national governments with tailored technical consulting in core areas such as (amongst other): economic development, trade and regional integration, educational and social reforms, institutional support, consumer protection, health, culture, monitoring and evaluation, migration, natural resources and agriculture. Next to our technical consulting activity, IBF also supports international funding agencies with the logistic organisation of events (seminars, workshops, study visits, etc). We use success stories and established approaches from various countries and see how these good practices can be adapted to our clients’ specific situation by working closely with them and local practitioners. We strive for excellence and results.
IBF’s goal is to position IBF as a consulting company that our clients will turn to. We provide tailored consulting advice in the field of development hand in hand with top experts and partners who are close to us, offering the right added value and solutions. We wish to be different by offering a new dimension to the consulting and event organisation business. Our clients will seek our added value, the best practitioners in every field will be attracted by IBF and our reputation as a bespoke development consultancy and event organiser will be consolidated.
IBF is passionate about its work. This zest and enthusiasm for achieving the very best is what differentiates IBF from many of our competitors and motivates us to excel in our commitment and overall service offering.
3. First key element of the Code of Ethics and Professional Conduct : preventing unwanted and unacceptable behaviour.
This first key element contains minimum standards of integrity and the commitment by IBF staff therefore entails an obligation of result.
3.1. Preventing corruption.
Preventing corruption, in its usual sense, is a common responsibility to which every individual working for IBF must contribute, by abstaining from and reporting about all acts of corruption.
Such acts include, directly or through an intermediary, requesting or receiving an undue advantage of any kind, or accepting the promise of such an advantage, for oneself or for a third party, in order to perform or refrain from performing any act in your capacity as IBF staff. They also include, the case being, any promising, offering or giving, directly or through an intermediary, to a person who in any capacity is involved in a public or private entity an undue advantage of any kind, for that person or for a third party, in order that that person should perform or refrain from performing any act, in breach of that person’s duties.
More generally, corruption can take the form of bribery, kickbacks, facilitation payments, collusion, embezzlement, undue payment for public service, gratuities, coercion, etc…
In addition, particular attention must be given to the following activities which, by their nature, imply a risk in terms of corruption :
– charitable and political contributions : these are only allowed if made unconditionally and strictly unilaterally ; any such contribution must moreover be preceded by a specific reporting to at least two Code of Ethics and Professional Conduct’s Contact Persons (including at least the Independent Director responsible for Ethics) and to the external Ethical Compliance Counsel.
– gifts and entertainment : gifts or business courtesies may never be provided nor received if they are being offered in exchange for an unfair business advantage or if offering them could create the perception of an improper motive. You should never request a gift or a business courtesy. Any gift or business courtesy of which the (apparent) value exceeds 250€ must be reported immediately to at least two Code of Ethics and Professional Conduct’s Contact Persons (including at least the Independent Director responsible for Ethics) and to the external Ethical Compliance Counsel. IBF expressly reserves the right to organise a system on special occasions, such as the Christmas period and the year’s end, whereby any and all gifts are handed over in order to be distributed amongst all IBF staff according to a tombola.
– reimbursement of travel and lodging expenses : since such would constitute an exception to the general practice of IBF bearing such expenses, a specific reporting is required for such reimbursements by third parties, identifying the travel and/or lodging, their cost and the amounts reimbursed as well as the business reasons for travel and lodging.
3.2. Preventing Conflicts of Interest.
a) Bias
IBF must at all times be able to make objective, prudent decisions, and to act with integrity. A personal interest in relation to a professional action is very likely to bias the professional judgment and by definition raises a potential conflict of interest. IBF staff should avoid putting themselves in a position where professional actions can be influenced by outside employment/directorships, personal or family relationships or other personal interests.
IBF staff must :
– Ensure that their professional judgments or assistance are not influenced by financial interests, personal activity, or family, business, or personal relationships.
– Disclose potential conflicts of interest when you have family, business, or personal relationships with an applicant, bidder, offeror, or awardee, and, more generally, disclose any interests and relationships that might affect or appear to affect your professional judgment. IBF management will subsequently intervene in order to limit or avoid the appearance of a conflict of interest, including the application of the so-called ‘four eyes principle’, meaning that all contracts and financial transactions need to be authorized by two people having the legal capacity to do so.
– Notify IBF Management immediately if a member of your family or someone with whom you have a personal relationship is applying for a job or other professional relationship with IBF. This will allow IBF to take appropriate action to avoid the appearance of conflict, for instance in terms of absence of participation in interviews, presentations, negotiations with respect to this job or contract.
– Avoid any direct or indirect financial interests with any competitor, supplier, or current or potential client. Exceptions to this rule include minimal, passive investments or those based on pre-existing relationships between the IBF staff and the organization in question, as long as they do not create a conflict or the appearance of a conflict of interest. In case of doubt, one is required to report to at least two Code of Ethics and Professional Conduct’s Contact Persons (including at least the Independent Director responsible for Ethics) and to the external Ethical Compliance Counsel.
– Notify to at least two Code of Ethics and Professional Conduct’s Contact Persons (including at least the Independent Director responsible for Ethics) and to the external Ethical Compliance Counsel, even in cases where there is no legal impediment or non-compete obligation, all outside professional activity, including functions within legal persons such as the function of a board member.
b) Unfair Advantage
Appearances are important when anticipating and managing situations of conflict of interest. Immediate action is required when one is confronted with such situations. IBF staff are responsible for assisting IBF to prevent conflicts of interest based on unfair advantage by :
– Assuring that our professional judgments or technical assistance are not influenced by any private economic interest. For example : having a direct family relationship with a company or the employee of a company that may benefit from our actions, owning or partially owning a firm or organization engaged with IBF, or serving on the board of a potential bidder or applicant.
– Refraining from seeking out non-public, procurement-sensitive information, such as the estimated value of a project, the timetable for consultations, the budget and financial previsions, or the terms of reference for the project. If such information is inadvertently received, immediately restrict access to it, ensure that it will not be used in the preparation of the tender and inform at least two Code of Ethics and Professional Conduct’s Contact Persons (including at least the Independent Director responsible for Ethics) and to the external Ethical Compliance Counsel.
– Avoiding the design or development of statements of work or terms of reference pertaining to solicitations for which IBF will be competing. Particular attention should be given in this field to the fundamental choice IBF may have to make in case IBF’s interest to participate in the project override the interest to participate in the pre-award activities. In these cases, everyone working for IBF must abstain from all implications or work regarding these pre-award activities.
– Avoiding contracts with former public officials and with entities and persons associated or related to them when the services to be rendered under such contract relate directly to the functions held or supervised by this formal public official and over which they continue to be able to exercise material influence.
3.3. Fraud.
Fraud is falsifying or withholding information in order to obtain personal or financial gain, also for others. Examples include falsified travel vouchers, invoices, time sheets, receipts, or other data that are relevant in a project. False representations with respect to qualifications is equally fraudulent.
Working for IBF, you are responsible for assisting IBF to prevent fraud by:
– Overseeing financial, procurement, and grant-related transactions to ensure the accuracy and completeness of information.
– Ensuring documentation in support of approvals is accurate and complete.
– Asking questions regarding documents, justifications, and performance, especially when you suspect inconsistencies.
– Independently verifying information or spot-checking information in quotations/bids.
– Monitoring and independently verifying performance of service or appropriate delivery of equipment/supplies according to the terms of the subcontract or award.
– Regularly assessing risks and revising policies and procedures as necessary.
3.4. Prevention of sexual exploitation, abuse and harassment.
IBF is committed to maintaining a culture of zero tolerance for sexual exploitation, abuse and harassment within its organization and in all activities carried out in pursuit of its mission and daily operations.
IBF commits to ensure that its staff (employees, interns, volunteers, freelancers and consultants) meet the general principles and logic of the obligations set out in the UN policies on PEASH (https://www.un.org/preventing-sexual-exploitation-and-abuse/content/policies-and-protocols) to prevent, address, and sanction incidents of sexual exploitation, abuse and harassment, as defined below:
– Sexual exploitation is considered the act of abusing or attempting to or attempt to abuse a state of vulnerability, unequal power or trust for sexual purposes, including relationship of trust for sexual purposes, including, but not limited to, financial, social or political advantage. Sexual exploitation is a broad term that encompasses acts such as paid sex, proposition of paid sex and exploitative relationships.
– Sexual abuse is considered a sexual violation committed with force, coercion or unequal relationship, or the unequal relationship, or the threat of such interference. Sexual abuse is a broad term that includes acts such as rape, sexual assault, forced prostitution, etc.
– Sexual harassment is considered any form of unwanted behaviour, verbal, non-verbal or physical conduct, of a sexual nature, having the purpose or the effect of violating the dignity of a person particularly when such behaviour creates an intimidating, hostile, degrading, humiliating or offensive environment.
IBF’s commitment is to provide a safe environment for all those who work with the organization or are beneficiaries, partners of the organization’s activities. IBF also expects every individual associated with it to strive to create an environment free of discrimination, harassment, or any other form of offensive or threatening behaviour; therefore, each individual working in any capacity with IBF is personally responsible for ensuring compliance with the standards outlined in this chapter and with the international standard policies and mechanisms (such as UN policies on PSEAH) and for reporting any situations that may raise concerns about conduct by IBF’s staff in violation of this chapter and the international standards (ref. chapter 5.1 (Reporting issues under the Code of Ethics and Professional Conduct) and 5.3 (The external Ethical Compliance Counsel) of the IBF Code of Ethics and Professional Conduct).
Moreover, to ensure that an effective PSEAH takes place, IBF established: i) An organizational culture that promotes prevention, accountability and transparency with regard to sexual exploitation, abuse and harassment; ii) Anonymous and confidential reporting mechanisms, which include effective, accessible and appropriate communication channels aimed at preventing retaliation against complainants, victims and witnesses ; iii) Impartial, fair and confidential investigation procedures to ensure that all allegations of sexual exploitation and abuse are addressed and followed up; iv) Support measures for any person who falls under this Code who is or has been a victim of sexual exploitation, abuse and harassment, or any person who makes a report and requests or needs such support, with due observance of confidentiality and safety requirements; v) Appropriate corrective measures in light of the circumstances in order to provide an adequate response to proven cases of sexual exploitation, abuse and harassment; vi) Appropriate sanctions in cases of proved sexual exploitation, abuse and harassment and/or in case of false allegation.
4. Second key element of the Code of Ethics and Professional Conduct : promoting good-faith and fair dealings and fair competition in case of IBF-tendering.
4.1. Good-faith and fair dealings with subcontractors and consultants.
In soliciting for services, subcontractors and consultants must be treated fairly, in accordance with IBF values. IBF policies and procedures are designed to quickly and fairly select those subcontractors, consultants and other implementing partners most likely to succeed, considering price, quality, and ability to deliver.
All contracts between IBF and its consortium partners and consultants will systematically include an adherence to the present Code of Ethics and Professional Conduct. Particular attention and explanation will be given, whilst negotiating and preparing work for IBF, to the unwanted and unacceptable behaviour as described in point 3. above.
Individuals, companies, and organizations may be subject to restrictions from various governments. At IBF, you play an important part in how we manage projects, and that responsibility entails ensuring the eligibility and responsibility of subcontractors and consultants. To qualify as responsible, a firm or organization must have the technical capacity, experience, and ability to perform and finance the assigned work (or must be able to obtain the necessary capacity and financing) given its current workload. Part of the eligibility determination may include vetting information against established Government and International Organization (for instance the U.N.) web-based databases. It is our responsibility to comply with these requirements to prevent engagement with terrorists, drug traffickers, criminals, and other prohibited entities. Failure to exercise due diligence can result in significant penalties and may damage IBF’s ability to win future projects. Contact any Code of Ethics and Professional Conduct’s Contact Persons in case of doubt or questions.
4.2. Fair competition when IBF is tendering and awarding.
In all situations whereby IBF is the procurement actor for a tender and an award, IBF and all IBF staff must be inspired by the following principles :
– as procurement actor, IBF must serve the interest of the project for which the tender is launched
– IBF must act in a transparent and accountable manner, both towards its partners in the project and towards the competitors in the tender
– all legal requirements related to the tender must be respected, taking into particular account the applicable law on the tender
– decisions related to the tender and the award must be taken in a fair and equitable manner, without being affected by bias
With respect to contacts with candidates, which are as such and in principle indispensable for a fair and just tendering, IBF and IBF staff must ensure that all candidates are treated in an equal manner, ensuring in particular that information given to one candidate will also and automatically be given to the others. This can include information on completed procedures, previously awarded contracts, with the exception of business secrets and other confidential information. Also, information about the project, the organisation, the involvement and activities of IBF and other operators or authorities involved, can in principle be disclosed on the condition of involving all candidates to the tender. As a general rule and in order to ensure an equal distribution, these communications must be made in writing.
On the other hand, information regarding draft documents holding relevant information with respect to the given tender, and these documents as such, cannot be disclosed to any candidate. A document is considered such a draft as long as it has not been publicised or communicated to the candidates for the tender.
In this situation where IBF is a procurement actor, the principles regarding prevention of corruption (above 3.1), conflict of interest (above 3.2) and fraud (above 3.3) apply with rigour. Moreover, no gifts or advantages whatsoever can be accepted from candidates for the given tender.
5. Third key element : the duty and the freedom to report and to cooperate in audits and enquiries.
5.1. Reporting issues under the Code of Ethics and Professional Conduct.
IBF staff should realize the importance to raise questions and to come forward with all concerns related to the issues of this Code of Ethics and Professional Conduct. Doing so reinforces IBF’s commitment to act ethically in every business decision there is to make. Early detection also allows IBF to address concerns before they become problems, and to take corrective action if necessary. Above all, IBF is committed to maintaining a culture where each of us feels comfortable asking questions, speaking up and working toward solutions.
To the extent that is legally possible, IBF shall treat all reporting that is done in line with this Code, in a confidential manner. When serious issues require an enhanced level of confidentiality, reporting can be made to the external Ethics Compliance Counsel, who is under a particular and legal obligation of confidentiality.
Code of Ethics and Professional Conduct’s Contact Persons and the Ethics Compliance Counsel promise to investigate all reports promptly, thoroughly and consistent with applicable law. Investigations will be kept confidential to the extent possible. If necessary, IBF may report certain investigations to the appropriate authorities. Our company will take appropriate corrective or disciplinary action for Code violations whenever necessary.
On top of the legal provisions protecting the so called “whistle blowers”, IBF does not tolerate acts of retaliation against anyone who makes an honest and selfless report of a possible violation of the present Code, or who participates in a subsequent investigation. Simply stated, it does not matter whether a report actually uncovers unethical behaviour, as long as it was made honestly and selflessly.
IBF expects its business partners to adhere to this same principle and not to tolerate any retaliation against their personnel reporting possible violations and subsequent investigations.
5.2. Cooperation : external audits and investigations.
External audits and investigations are an important oversight responsibility of IBF towards the beneficiaries and contracting authorities. This responsibility primarily lies with the executive management, so please notify this management when contacted by an external auditor or investigator. But it can also necessitate cooperation and disclosure of any other IBF staff. All such persons are expected to faithfully cooperate with audit and investigation efforts, to be available for interviews when requested and to provide timely and reasonable access to documents for review. Here, again, IBF will not tolerate acts of retaliation against anyone who cooperates in an honest and sincere manner.
Note that requests for information by an external auditor or investigator should be made in writing so that IBF may track the request and the provision of the information. Copies of original documents can be provided to auditors or investigators on the condition of obtaining a detailed receipt or inventory.
5.3. The external Ethical Compliance Counsel
As already indicated in this Code, IBF has appointed an external Ethical Compliance Counsel in order to enhance confidentiality with respect to reporting, especially in sensitive and possibly difficult situations, in particular those in which questions regarding the prevention of corruption, conflicts of interests or fraud arise.
This Counsel is : Mr. Michaël Verhaeghe, advocate at the Brussels’ bar, who can be contacted preferably via mobile phone (+32 475 549 646) or email (ecc@ibf.be)
6. Additional overall ethical principles
6.1. Confidential information and business secrets
IBF staff must be vigilant in protecting proprietary and confidential information obtained in the performance of their work. Any information which, if released, would have an adverse impact on an individual’s privacy or a business/organization’s competitiveness, or on client programs or their foreign relations, is considered proprietary or confidential and must be controlled and restricted. Examples of proprietary or confidential information include non-public procurement-sensitive information, financial reports, financial performance documents, financial plans, medical and personal information, and IBF proposal details. You may not disclose any non-public information related to the client, implementing partners, or beneficiaries for any reason. If you need to send confidential information outside IBF, the approval of a Code of Ethics and Professional Conduct’s Contact Persons or a non-disclosure agreement may be needed.
6.2. Excellence
IBF is committed to achieving the highest technical and professional standards. We ensure that services performed and products provided meet or exceed the quality specifications in contracts and other customer agreements by establishing and monitoring oversight systems, maintaining substantiating evidence, documenting authorizations and approvals, and conducting training and regular reviews of performance.
Maintaining a constructive and collaborative business relationship with IBF’s partners and clients is essential to IBF’s success. IBF staff is expected to assist in this process by responsibly managing contractual, legal, policy, and professional matters, and meeting all ethical requirements. Our partners and clients rely on us for appropriate solutions and responsible management of their resources. You should bring to the immediate attention of a Code of Ethics and Professional Conduct’s Contact Persons any concerns raised by partners or clients, or their representatives so that we can take control of the issue and respond appropriately.
6.3. Global Citizenship
a) Safe, Secure, and Healthy Work
IBF will ensure that appropriate arrangements, processes, and procedures are in place to provide a secure workplace, taking into account the operating environment and level of risk involved in the performance of the work. IBF staff, and in fact all persons working for IBF, are expected to be alert to working surroundings to avoid vulnerable situations and must immediately report any threats or incidents in relation to safety and wellbeing at work. For all further information and details, IBF staff is requested to contact the internal prevention advisor, as foreseen in the relevant Belgian statute law.
IBF’s diversity is essential to its success as a global company. We treat others as we would like to be treated ourselves. We value each other’s work and roles within the organization. This respect builds trusting relationships that promote teamwork and nurture an organizational climate that is fair, supportive, and responsive. We recognize that our words and actions are crucial to maintaining this professional environment.
IBF is committed to maintaining a work environment where all employees feel respected, valued, and free of harassment.
In cases of gender-based misconduct, IBF will ensure that the claimant(s) have access to assistance by his/her preferred gender.
b) Child Protection
IBF staff must be aware of the problem of child abuse and the risks to children. When children are involved, directly or indirectly, in projects where IBF is involved in –other than projects of an educational nature- then particular assessment and attention will be given to the safety and wellbeing of those children. IBF will ensure that action is taken to support and protect children where concerns of abuse arise.
c) Political Activities
IBF does not fund political contributions, in cash or in kind, anywhere in the world. This prohibition includes support of political activity, political parties or their representatives, political campaigns, and candidates or any of their affiliated organizations.
IBF staff has the right to engage in their personal capacity in the political process and make political donations, as long as they do not represent that IBF is making the contribution and provided there is no conflict of interest involved.
d) Communicating with Media and the Public
If IBF staff is contacted by a member of the media, they should refer the individual to the executive management of IBF.
e) Using Information, Email, and Social Media Responsibly
IBF uses global electronic communications and resources as a routine part of business activities. IBF staff cannot use electronic media to initiate, save, or send items that are hostile, harassing, offensive, threatening, or inappropriate; to initiate, save, or send chain letters or other widespread non-business distributions; or to initiate or participate in any malicious, unauthorized, or fraudulent use of company resources. Also, IBF staff must avoid soliciting for commercial, charitable, religious, or political causes and interfering with or disrupting network users, services, or equipment. Gaining unauthorized access to databases or information sources or damaging computer equipment, software, or data constitute serious breaches of contract.
7. Adherence and (re-)commitment to the Code of Ethics and Professional Conduct – training and awareness – responsibility of managers and supervisors – exceptions.
Once a year and at each revision of the Code, all IBF staff shall certify, in writing that they recommit themselves to the Code of Ethics and Professional Conduct and that they have reported all possible violations of the Code in accordance with its reporting obligations, as laid down in point 5.
On an annual basis and after each material update of the Code, IBF will organize training sessions in order to enhance awareness and compliance amongst IBF staff. In case an incident occurs with respect to this Code of Ethics and Professional Conduct, IBF may organize a specific awareness event with respect to this incident. IBF staff is required to participate in these sessions and events.
IBF staff in a position of manager, supervisor or team leader are responsible for ensuring that other IBF staff understand and follow the Code of Ethics and Professional Conduct. They must establish and maintain a workplace culture in which IBF staff feel comfortable doing what is right and uncomfortable doing what is wrong.
This Code of Ethics and Professional Conduct is governed by the “comply or explain”-principle. Exemptions from its provisions can only be granted, by the board of directors, upon clear and duly motivated explanation, recorded in writing and in compliance with the fundamental principles of the Code of Ethics and Professional Conduct, meaning, for instance, that no exemptions are possible with respect to the rules regarding corruption and fraud, and that exemptions can never result in a violation of law.
8. Code of Ethics and Professional Conduct’s Contact Persons: composition and contact details.
Below you find the composition of the Code of Ethics and Professional Conduct’s Contact Persons, together with the contact details:
. Frédéric André, Chairman, Managing Director; Email: andre@ibf.be
.Riccardo Innocenti, Director; Email: innocenti@ibf.be
.M. Antonio Barbero, Independent Director responsible for Ethics; Email: antonio.barbero@polito.it
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