Code of Conduct

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CODE OF CONDUCT

Valid from 06.01.2025
The following code of conduct will be included in every contract SwB enters into with
partners in the South.
This code of conduct applies within SwB’s own membership as well as to actors (partners in the
South and other partners) who are in a contractual relationship with SwB and includes all persons,
institutions, companies and organizations with whom SwB collaborates. That is, everyone who receives funds from the Civil Society Development Fund (CISU) to carry out a task, deliver a service
or who receives funds to carry out information, development and/or humanitarian work in connection with the preparation and implementation of SwB’s projects.
GENERAL BEHAVIOUR
SwB members who, as part of a project group, are active in one or more civil society projects must
act with respect for the culture, customs and traditions of the country/local population in question
and must regard the partner as an equal and with trust. Members must also comply with local
laws and regulations.
To the extent that irregularities of any kind are observed, members must report this to CISU within
14 days.
All irregularities are reported to the National Board of SwB as soon as the irregularity is observed
or there is suspicion of irregularities. The National Board must take immediate action if the project
group cannot solve the problem locally, and the partner must be supported in reporting any irregularity to SwB/CISU/local authorities. Reports can be made anonymously.
ANTI-CORRUPTION POLICY
No offer, payment, consideration or advantage of any kind that may be considered an illegal or
corrupt practice may be given – either directly or indirectly – as an inducement or reward in connection with the tender, the award of the contract or the performance of the contract. Any such
practice will be grounds for the immediate cancellation of this contract and for such further actions, civil and/or criminal, as may be appropriate. At the discretion of the Ministry of Foreign
Affairs, a further consequence of any such practice may be the definitive exclusion from any tender
for projects financed by the Danish Ministry of Foreign Affairs. Likewise, any misuse of allocated
funds for personal gain will be considered a breach of SwB’s anti-corruption policy.
Corrupt and fraudulent practices include the following acts:
1. Fraud and fraudulent conduct refer to deliberate acts committed by individuals for personal
gain. It includes misrepresentation, extortion, collusion, nepotism, theft, embezzlement, forgery
and misleading or fraudulent reporting of costs associated with project activities, travel expenses,
per diems, etc.
2. Bribery. It is corrupt conduct and practice when payment is offered in excess of normal rates in
exchange for special services or expedited processing of cases (also known as “smearing” and
“bribe”).
3. Misappropriation of funds. This is understood as the use of money and assets (such as the
purchase of equipment not for the project, failure to store assets securely, use of equipment for
private use, etc.) for purposes other than those stated in the application for funding for the projects
and activities in question, as well as negligent or inappropriate maintenance of assets.
4. Severe irregularities. This concerns inadequate bookkeeping, delayed or non-existent reporting to partners and donors, waste in the management of material, financial and human resources
and other forms of failure due to lack of project management, etc.
5. Acceptance of and offer of major gifts. Acceptance of, or offer of, gifts or services that are
more than symbolic, i.e. other than pens, calendars, etc. You are welcome to bring and/or receive
small gifts, such as cookies, scarves, etc. in connection with visits to the partner country, as this is
part of the social context. No one may directly or indirectly request or receive any gift, service or
other value in exchange for actions or omissions at work, or which influence – or appear to influence – the performance of his/her functions, duties or judgment. This also applies to values that
are transferred to third parties, such as spouse/partner, children, etc.
6. Confidentiality. Confidentiality includes, among other things, concealment or concealment of
matters in contract management or of potential conflicts of interest in cooperation with partner
organizations, service providers, suppliers and collaborators. This includes any attempt to conceal
close family ties, financial interests and other crucial matters in relation to confidentiality and
disqualification.
7. SwB and partners. SwB and its partners may neither actively nor passively contribute to corruption, bribery or fraud in accordance with the above. Regardless of local custom, SwB will not
compromise our integrity. We will not – neither in Denmark nor abroad – give, provide, request or
receive gifts or other benefits that have more than a symbolic value and that may affect our impartiality or judgment.
8. Follow-up on suspicion of or evidence of corruption. If SwB or a partner becomes involved
in bribery or corruption, knowingly or unknowingly, with or without conscious intent, SwB must
immediately take the necessary steps to follow up on the matter. Follow-up must be done with the
partner and by reporting to (CISU).
The project group and the national board jointly coordinate further measures in the C-case with
CISU. The decision-making authority regarding C-cases lies with the Ministry of Foreign Affairs
and the National Audit Office.
ANTI-TERROR POLICY
If Seniors Without Borders (SwB) discovers any connection whatsoever with an organization or
person associated with terrorism (cf. the EU list of terrorist organizations), SwB shall immediately
inform CISU and the Danish Ministry of Foreign Affairs (UM) and explain the reasons for such a
report, including whether the connection was made knowingly, voluntarily, accidentally, unintentionally, fortuitously or under the influence of force.
SwB agrees that SwB itself and/or its partners (including suppliers, subcontractors and associated
grant recipients) will take all reasonable steps to ensure that no transaction carried out in relation
to the project/programme – directly or indirectly – will benefit a person, group or entity subject
to UN or EU restrictive measures. Any breach of this clause is grounds for immediate termination
of the contract and the return of all funds provided to the partner in the project to CISU.
Valid from 06.01.2025
ANTI CHILD-LABOUR POLICY
The partner must comply with applicable national laws and applicable international agreements,
including the UN Convention on the Rights of the Child and ILO (International Labour Organization, a UN body) conventions. Any violation will be grounds for immediate termination of the
agreement.
PROTECTION POLICY (PSHEA CLAUSE)
All persons have the right to a life free from sexual harassment, exploitation and abuse of power.
SwB does not tolerate sexual harassment, exploitation or abuse of power, either internally or exernally among anyone associated with our work.
SwB has a zero-tolerance approach to passive approach to tackling sexual exploitation, abuse and
sexual harassment, which is enshrined in Danish criminal law and defined as follows by the UN:
Harassment is any inappropriate and unwelcome conduct that can reasonably be expected or
perceived to cause offence or humiliation to another person.
Sexual exploitation: Any actual or attempted abuse of a position of vulnerability, or trust for sexual purposes, including, but not limited to, making money, socially or politically from the sexual
exploitation of another.
Sexual abuse: Actual or threatened physical penetration of a sexual nature, either by force or
under unequal or coercive conditions.
Based on human dignity and the right to safety, SwB actively works against sexual exploitation
and abuse of power.
SwB prevents potential sexual exploitation and abuse of power and acts immediately when abuse
has occurred or is suspected. SwB follows up on all cases to be able to sanction, protect, help and
learn.
All parts of SwB’s and partners’ organizations must actively contribute to the protection of persons
who are in contact with SwB’s projects, directly or indirectly. SwB and its partners must take appropriate measures to protect individuals, including beneficiaries and staff, from Sexual Harassment, Exploitation and Abuse (PSHEA) carried out by SwB’s volunteers and associated staff, including individuals in the partner organization and personsin the target group of the project, and
take timely and appropriate action when reports of PSHEA arise. In these cases, SwB shall take
timely and appropriate action to investigate the allegations and take disciplinary or civil and/or
criminal action.
Any violation of this clause may result in immediate termination of the partnership agreement and
closure of the project.
Reporting of suspicions and/or findings of Sexual Harassment, Exploitation and Abuse shall be
made to: formand@seniorerudengraenser.dk
COMPLAINT AND REPORTING SYSTEMS:
Any complaint about incidents during the project period regarding suspicions of corruption and
terrorism must be addressed to the project manager and the SwB chairman and reported to CISU
on a separate form available on the CISU website within 14 days.
Valid from 06.01.2025
Reporting on PSHEA must exclusively be addressed by e-mail to formand@seniorerudengraenser.dk
Contact information for both the project manager and the SwB national chairman must be immediately available to partners – e.g. by posting on a notice board.
Seniors Without Borders’ complaint system includes the acceptance and processing of anonymous
reports. The executive committee and the project manager (if he is not personally covered by the
report) will work together to reach the right procedure and an orderly decision. All inquiries are
processed anonymously in this group. When a decision has been made, the other members of the
SwB board and the partner involved will be informed of this.
Any breach of the SwB Code of Conduct shall be investigated within the applicable disciplinary
procedures and agreements or referred to local authorities for criminal investigation in accordance with the laws of the country where the project is being carried out. Violation of the Code of
Conduct may result in sanctions, including disciplinary measures resulting in possible dismissal or
termination of all relationships and contractual partnership agreements. If an investigation is initiated based on a legitimate suspicion of abuse directed at another person and this suspicion
proves to be unfounded, no action shall be taken against the person reported. The Board will respond in cases of false or malicious accusations.
WHISTLEBLOWER REGULATION
Any member of SwB, SwB’s partner organization, project target group, suppliers and subcontractors, and associated grant recipients, has the right, anonymously, to report irregularities by e-mail
to formand@seniorerudengraenser.dk
PROCEDURE FOR REPORTING IRREGULARITIES (CORRUPTION)
If there is suspicion of irregularities regarding corruption and/or terrorism during the implementation of a project funded by CISU, the following procedure will be initiated immediately.
1. Report to CISU no later than 14 days after the suspicion arises via: (https://cisu.dk/media/mtoafdyw/eng-form-for-reporting-of-irregularities.doc)
2. Simultaneous contact from the project manager to the partner in the South and the chairman
of SwB
3. The partner must immediately explain the circumstances that form the basis for the suspicion.
4. The national chairman and the project manager jointly make demands on the partner regarding: repayment of missing funds, replacement of the responsible person(s) at the partner and external audit of the partner’s accounts. The demands may include reporting to the police to local
authorities and possibly freezing project funds and, ultimately, closing the project and repayment
of unused funds.
5. SwB coordinates with, and seeks advice from, CISU on which of the above sanctions should be
applied.
6. It is the responsibility of CISU to forward the report to the Ministry of Foreign Affairs
(UM) and the National Audit Office, which has the decision-making authority regarding Ccases (corruption).

Valid from 06.01.2025