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WHO Policy on Prevention, Detection and Response to Fraud and Corruption

This policy encapsulates WHO’s existing rules and practices regarding fraud and corruption. Which builds on anti-fraud and anti-corruption practices promoted by leading international professional bodies and peer organizations, particularly within the United Nations (UN) system, to adopt a contemporary definition of fraud and corruption and set forth robust mechanisms to combat them.

This policy applies to the following categories of individuals and entities:

  • WHO staff
  • WHO individual collaborators
  • Third party entities such as vendors, contractors, grant recipients and technical partners
  • Other entities and individuals who receive WHO funds, execute a project or perform any other work or activities in the name of or for the benefit of WHO; and
  • Individuals or their legal representatives who are eligible for WHO entitlements and insurances, such as dependents, retirees and other eligible family members.

Context of this Policy

1. Fraud and corruption are serious threats to any organization; no organization is immune to them.

2. As established in its Constitution, WHO’s objective is “the attainment by all peoples of the highest possible level of health”.

3. Combating fraud and corruption is therefore critical if WHO is to achieve its mission and mandate.
The occurrence of fraud and corruption would also be in contradiction with WHO’s code of ethics and professional conduct, which articulates principles of independence, impartiality, integrity, respect and professional conduct.

4. Fraud and corruption pose significant risks to WHO, and may be harmful to its objectives, reputation and effective governance.

5. In maintaining a framework to effectively manage these risks, WHO provides assurance to its Member States, donors and the public that integrity and accountability are key intrinsic features of all its activities.

6. WHO is committed to addressing fraud and corruption through the cycle of “prevent, detect and respond”.

7. WHO works within a results-based management framework that calls for delegated responsibility, authority and accountability in a decentralized environment at all levels of the Organization as defined in WHO’s Accountability Framework.

The following practices will be referred to in this policy as “fraudulent or corrupt practices” or “prohibited” practices:

  • Fraud or fraudulent practice is any act or omission, including any misrepresentation, that knowingly misleads, or attempts to mislead, a party to obtain any financial or other benefit or to avoid an obligation, whether for oneself or for others.
  • Corruption or corrupt practice is the offering, giving, receiving or soliciting, directly or indirectly, of anything of value to influence improperly the actions of another party. It may reflect an abuse of power or improper use of resources for private gain.
  • Theft or misappropriation is the unauthorized taking of anything of value that belongs to another party.
  • Collusive practice is an arrangement between two or more parties designed to achieve an improper purpose, including improperly influencing the actions of another party. To avoid any doubt, this includes, without limitation, any arrangement involving covered parties that is intended to override this policy and WHO’s framework to prevent fraud and corruption, or may have that effect or result.
  • Coercive practice is impairing or harming, or threatening to impair or harm, directly or indirectly, any party or the property of the party to influence improperly the actions of a party.
  • Obstructive practice is deliberately destroying, falsifying, altering or concealing evidence relevant to an investigation or making false statements to investigators in order to materially impede an investigation into allegations of corrupt, fraudulent, coercive, or collusive practice; and/or threatening, harassing or intimidating any party to prevent it from disclosing its knowledge of matters relevant to the investigation or from pursuing an investigation; or acts intended to materially impede the exercise of investigation and audit rights or failing to comply with the duty to report as defined in the WHO Whistleblowing and Protection Against Retaliation Policy, or under relevant obligations of this policy.
  • Money laundering is the conversion, transfer, acquisition, possession or use of property by any party who knows, or who may be reasonably presumed to know, that such property is derived from criminal activity or from participation in such activity, including the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, such property, or aiding, abetting and facilitating such acts.
  • Financing of terrorism is the provision or collection of funds, by any means, directly or indirectly, with the intention that they should be used, or in the knowledge that they are or will be used, in full or in part, to benefit individuals and entities subject to sanctions imposed by the United Nations Security Council and appearing on the United Nations Security Council Consolidated List.
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