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Management Accountability at 17�Թ���

17�Թ���’s long history of successfully implementing projects worldwide is built upon the commitment of our staff and the implementation of strong ethical practices. Since our founding, honesty, integrity, and accountability have formed the foundation underlying our work and shaped our culture. We recognize that 17�Թ���, and all our employees, have a responsibility and obligation to conduct 17�Թ���’s business in an ethical and legal manner.

17�Թ��� defines management accountability as engaging in ethical and legal behavior, establishing sound management practices, making informed decisions, and being responsible stewards of donor funds. Accountability is critical for achieving our mission and we are committed to maintaining the highest standards of ethics and compliance.

17�Թ���’s Management Accountability Framework is designed to support a culture of ethical behavior, responsibility, and compliance. 17�Թ��� fully-integrated approach to management accountability means that operations and financial management functions are embedded in our projects and actively supported by our dedicated Contracts and Compliance Team. This ensures that 17�Թ��� abides by its core values and the laws and regulations governing our business. We apply these practices consistently in all our operations and in every country where we work.

The Management Accountability Framework has six components that build on each other and ensure accountability in all our work:

• Culture: 17�Թ��� continually reinforces a culture based on six ethical pillars: honesty, integrity, diligence, fairness, trust, and respect.
• Management: The management structure supports the culture and oversees implementation of key controls.
• Training: All staff are trained in 17�Թ���’s cultural norms, controls, and resources.
• Controls: Appropriate controls are in place to ensure that 17�Թ���’s culture and systems are respected, honored, and lived.
• Resources: Appropriate resources are available to all staff to perform their duties efficiently, effectively, and with integrity.
• Reporting: Mechanisms are in place for staff to report a concern or a lapse in any component of the accountability framework.

How to Report a Concern

17�Թ��� takes reports of possible unethical, illegal, fraudulent, or improper conduct seriously. 17�Թ��� Code of Conduct Helpline is your resource for reporting such conduct, a lapse in any component of our accountability framework, or any other concern. The Helpline is accessible to everyone: staff, consultants, subcontractors, vendors, and others.

17�Թ���’s Code of Conduct Helpline uses the EthicsPoint reporting system, which is hosted by our third-party hotline provider, NAVEX Global. The information you provide is received by NAVEX Global and sent to 17�Թ��� on a totally confidential and, if you should choose, anonymous basis.

Reporting a concern quickly brings the matter to 17�Թ���’s attention, initiating a process for a fair and thorough investigation. If you are unsure whether you should report an incident, please submit a report. Please do not start investigating suspected fraud on your own.

• Report Online:
• Report by Phone: Code of Conduct Helpline U.S. toll-free telephone: 1.855.715.2899

For any other location, please check the above website to find the local, toll-free telephone number in your country.

The 17�Թ��� Whistleblower policy encourages employees who become aware of wrongdoing in the organization to report their concerns without fear of retaliation. Employees are protected from adverse actions in retaliation for reporting concerns.