HakiElimu has a “Zero Tolerance” approach to Fraudulent, corrupt practices, Sexual Exploitation and Abuse (SEA) and does not allow any of its staff, Volunteer, interns, Board member, partner, supplier, sub-contractor, agent or any individual engaged by HakiElimu to engage in any form of the said Misconducts.

Fraudulent and Corrupt Practices include:

1. A Corrupt Practice is the offering, giving, receiving, or soliciting, directly or indirectly, anything of value to influence improperly the actions of another party;
2. A Fraudulent Practice is any act or omission, including a misrepresentation, that knowingly or recklessly misleads, or attempts to mislead, a party to obtain a financial or other benefit or to avoid an obligation;
3. A Coercive Practice is impairing or harming, or threatening to impair or harm, directly or indirectly, any part or the property of the party to influence improperly the actions of a party;
4. A Collusive Practice is an arrangement between two or more parties designed to achieve an improper purpose, including influencing improperly the actions of another
5. A Misconduct is a failure by a staff member to observe the rules of conduct or standards of behavior prescribed by HakiElimu (the Organization).
6. The  Standard of proof/shall be used to determine whether a complaint is substantiated,

Sexual Abuse” is the threatened or actual physical intrusion of a sexual or sexualized nature, including inappropriate touching, by force or under unequal or coercive conditions, sexual assault, rape and Sodomy. It may also include threatened or actual non-physical intrusion (unwanted and/or uninvited exposure to pornography, texts, images, and so on, the sharing of images, texts, and so on, demands for sexualized photographs, etc.).

“Sexual Exploitation” is any actual or attempted abuse of a position of vulnerability, differential power, trust, or dependency for sexual or sexualized purposes. This includes the offer or promise of monetary, social, or political benefits as an incentive or form of coercion.

In line with Admin Policy, Financial Regulations and Code of Conduct, HakiElimu staff, volunteers, interns, any people working with or on behalf of HakiElimu, partners, stakeholders or any other person is required to disclose acts related to fraud, corruption, sexual exploitation and abuse or any other misconduct that come to their attention. However, Whistle blowing and complaints should be made in the reasonable belief that what is being reported is true.

HakiElimu assures that a person who report acts of fraud, corruption, sexual exploitation and abuse or any other misconduct that affects the organization will not be disclosed and will be protected from retaliation.