This integrity violations and incident reporting mechanism is intended for any person who has observed or witnessed any integrity violations and has experienced or witnessed unwelcome behavior by a GCA staff member, consultant, vendor or a staff member of a GCA partner. GCA aims to maintain the highest standards of openness, decency, integrity and accountability in its work

• GCA encourages all personnel to speak up and report any concerns in line with GCA’s policies and procedures on complaints and grievances.
• GCA expects personnel to act honestly and ethically, and to make any report in good faith and on reasonable grounds.
• GCA commits to its obligation to protect whistleblowers or anyone who participates in an investigation of them from reprisal.
• GCA commits to maintain confidentiality of all reports and protect the identity of reporters to the fullest extent possible.

The report can be filed anonymously and/or on behalf of someone else. GCA will take your complaint seriously and investigate it thoroughly even if it reported anonymously. However, please note that anonymity provides fewer opportunities to access the primary source of information, i.e. the person who files a report.

It is useful to know that you can report an incident even if you lack strong evidence, as long as you are acting in good faith. If you have a genuine concern, GCA encourages you to report it. GCA’s independent compliance function will investigate in accordance with our policies and procedures, including an assurance of no repercussions to those reporting the incident.

Please note that this is not an emergency response mechanism. GCA cannot guarantee to be able to respond swiftly enough in situations where one or more people are in immediate danger. In such instances, please contact your local authorities.

NOTE: Every GCA employee, irrespective of their role, is defined as a team member.

The Internal Audit and Compliance Manager of GCA serves as the initial point of contact for all allegations of integrity violations. Such violations include:

• A corrupt practice is the offering, giving, receiving, or soliciting, directly or indirectly, anything of value to influence improperly the actions of another party.
• A fraudulent practice is any act or omission, including a misrepresentation, that knowingly or recklessly misleads, or attempts to deceive.
• A coercive practice is impairing or harming, or threatening to impair or harm, directly or indirectly, any party or property of the party, to influence improperly the actions of a party.
• A collusive practice is an arrangement between two or more parties designed to achieve an improper purpose, including influencing improperly the actions of another party.
• A conflict of interest is any situation in which a party has interests that could improperly influence that party’s performance of official duties or responsibilities, contractual obligations, or compliance with applicable laws and regulations.

Should you encounter difficulties accessing the online complaint form, please send an email to speakup@gca.org.

The Internal Audit and Compliance Manager of GCA serves as the initial point of contact for all allegations of sexual exploitation, abuse and harassment incidents, defined as follows:

• Sexual exploitation is any actual or attempted abuse of a position of vulnerability, differential power, or trust for sexual purposes. It includes profiting monetarily, socially or politically from the sexual exploitation of another.
• Sexual abuse is actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. This would include forced marriage and sexual slavery and also includes sexual activity with a child (any person under the age of 18).
• Sexual harassment is any unwelcome sexual advance, request for sexual favor, verbal or physical conduct or gesture of a sexual nature, or any other behavior of a sexual nature that might reasonably be expected or be perceived to cause offense or humiliation to another. Examples are staring, unwelcome familiarity (e.g. affection, touching), suggestive comments/jokes, insults/taunts of sexual nature, intrusive statements about private life, displaying posters/magazines/screens of a sexual nature, sexually explicit emails/messages, requests for sex or to go out on dates, offensive behavior.

Should you encounter difficulties accessing the online complaint form, please send an email to safeguarding@gca.org.