Anti-Fraud & Anti-Corruption Policy

Anti-Fraud & Anti-Corruption Policy

Ojeev Foundation

Effective Date: 12 May 2026
Last Updated: 27 June 2026

1. Introduction

Ojeev Foundation (“Foundation”, “we”, “our”, or “us”) is committed to conducting all of its charitable, social, educational, environmental, cultural, and humanitarian activities with the highest standards of integrity, honesty, transparency, accountability, and ethical governance.

As a registered Section 8 Company operating under the laws of India, Ojeev Foundation maintains a zero-tolerance approach toward fraud, corruption, bribery, embezzlement, financial misconduct, forgery, abuse of authority, conflicts of interest, and every other form of unethical or unlawful behavior.

This Anti-Fraud & Anti-Corruption Policy establishes the principles, responsibilities, reporting procedures, investigation process, and disciplinary actions applicable to all individuals associated with Ojeev Foundation.

This policy applies regardless of the value involved, the individual’s position, or the location where Foundation activities are conducted.

2. Purpose of this Policy

The objectives of this policy are to:

• Protect the Foundation’s financial and non-financial resources.
• Safeguard donor contributions.
• Promote transparency and ethical conduct.
• Prevent misuse of charitable assets.
• Ensure compliance with Indian laws and applicable regulations.
• Protect beneficiaries from unethical practices.
• Maintain public confidence in the Foundation.
• Encourage responsible reporting of misconduct.
• Provide a clear process for investigation and corrective action.

3. Scope

This policy applies to:

• Directors
• Trustees
• Board Members
• Advisory Committee Members
• Employees
• Volunteers
• Consultants
• Interns
• Contractors
• Vendors
• Suppliers
• Service Providers
• CSR Partners
• Grant Recipients
• Donors
• Event Organizers
• Temporary Staff
• Third-Party Representatives
• Any person acting on behalf of Ojeev Foundation

Compliance with this policy is mandatory.

4. Policy Statement

Ojeev Foundation strictly prohibits:

• Fraud
• Bribery
• Corruption
• Kickbacks
• Financial manipulation
• Theft
• Misappropriation of funds
• Misuse of Foundation property
• Forgery
• Falsification of documents
• Money laundering
• Undisclosed conflicts of interest
• Abuse of authority
• Nepotism
• Unauthorized payments
• False expense claims
• Procurement fraud
• Donation misuse
• Grant misuse
• Cyber fraud
• Identity fraud
• Any attempt to conceal unethical conduct

No individual has the authority to approve, ignore, conceal, or justify fraudulent behavior.

5. Ethical Principles

Every individual associated with Ojeev Foundation shall:

• Act honestly.
• Protect Foundation assets.
• Respect donor trust.
• Avoid conflicts of interest.
• Report suspicious activities.
• Maintain accurate records.
• Cooperate during investigations.
• Follow all applicable laws.
• Never misuse authority.
• Treat beneficiaries fairly.

6. Definition of Fraud

Fraud refers to any intentional act designed to obtain an unlawful, unfair, or unauthorized benefit through deception or dishonesty.

Examples include:

• Theft of cash
• Theft of donations
• Theft of equipment
• Fake invoices
• False accounting
• Duplicate payments
• Fake beneficiaries
• Forged signatures
• False reimbursement claims
• Payroll fraud
• Procurement fraud
• Fake attendance records
• Donation diversion
• Grant misuse
• Unauthorized bank transfers
• Identity theft
• Cyber-enabled financial fraud

This list is illustrative and not exhaustive.

7. Definition of Corruption

Corruption includes any dishonest misuse of power or authority for personal or organizational gain.

Examples include:

• Accepting bribes
• Offering bribes
• Demanding favors
• Accepting kickbacks
• Favoritism
• Nepotism
• Manipulating vendor selection
• Awarding contracts unfairly
• Misusing Foundation influence
• Receiving personal benefits in exchange for official decisions

8. Bribery

No employee, volunteer, trustee, contractor, or representative may:

• Offer bribes.
• Accept bribes.
• Request bribes.
• Promise illegal benefits.
• Facilitate unlawful payments.

This applies to:

• Government officials
• Vendors
• Corporate partners
• Donors
• Contractors
• Beneficiaries
• Private organizations
• Individuals

Both direct and indirect bribery are prohibited.

9. Misuse of Donations

All donations received by Ojeev Foundation shall be used exclusively for legitimate charitable purposes.

No individual may:

• Divert donations for personal benefit.
• Spend donations without authorization.
• Misrepresent the use of donated funds.
• Conceal financial transactions.
• Create fake donation records.
• Manipulate donation receipts.

All donations shall be accounted for accurately and transparently.

10. Financial Integrity

The Foundation shall maintain accurate, complete, and transparent financial records.

Financial records must:

• Be truthful.
• Be supported by documentation.
• Reflect actual transactions.
• Be retained according to legal requirements.
• Be available for authorized review and audit.

No false accounting entries may be created.

11. Procurement Integrity

All procurement activities shall be conducted fairly and transparently.

Selection of vendors shall be based on:

• Quality
• Competence
• Cost-effectiveness
• Compliance
• Ethical standards

No employee may manipulate procurement decisions for personal benefit.

12. Gifts, Hospitality, and Benefits

Individuals associated with Ojeev Foundation must not accept or offer gifts, favors, hospitality, or benefits that could improperly influence professional decisions.

Nominal courtesy items of insignificant value may be accepted where legally permissible and where they do not create a conflict of interest. Any significant gift or benefit must be disclosed to the Foundation.

Cash gifts or cash equivalents must never be accepted.

13. Conflict of Interest

All individuals must avoid situations where personal interests conflict with the interests of Ojeev Foundation.

Conflicts may include:

• Family relationships with vendors
• Personal financial interests
• Ownership in supplier companies
• Receiving commissions
• Personal business dealings
• Employment outside the Foundation affecting impartiality

Any actual, potential, or perceived conflict must be disclosed promptly.

14. Record Keeping

All official records must be:

• Accurate
• Complete
• Current
• Secure
• Verifiable

No person may intentionally:

• Destroy records
• Alter records
• Conceal records
• Fabricate documents
• Misrepresent information

15. Reporting Suspected Misconduct

Anyone who suspects fraud, corruption, bribery, financial misconduct, or unethical behavior is encouraged to report it immediately.

Reports may be submitted through:

Email: info@ojeev.org

Postal Address:

Ojeev Foundation
B3, Basement, A44, Sector 2, Noida, Uttar Pradesh – 201301

Reports should include, where possible:

• Nature of the concern
• Date and time
• Individuals involved
• Supporting documents or evidence
• Any relevant witness information

Anonymous reports may be accepted where sufficient information is provided to enable an investigation.

16. Investigation Procedure

Upon receiving a complaint, the Foundation may:

• Record the complaint.
• Conduct a preliminary assessment.
• Preserve evidence.
• Interview relevant individuals.
• Review documents and financial records.
• Engage external experts where necessary.
• Prepare findings.
• Recommend corrective actions.

Investigations will be conducted fairly, confidentially, and without bias.

17. Confidentiality

All reports, investigations, evidence, and related information shall be handled confidentially to the maximum extent permitted by law.

Information will only be shared with individuals who have a legitimate need to know.

18. Protection Against Retaliation

Ojeev Foundation prohibits retaliation against any individual who, in good faith, reports suspected misconduct or participates in an investigation.

Retaliation may include:

• Harassment
• Threats
• Discrimination
• Demotion
• Dismissal
• Intimidation
• Unfair treatment

Any retaliatory action will itself be treated as a serious violation of this policy.

19. Disciplinary Actions

Violations of this policy may result in one or more of the following actions:

• Verbal warning
• Written warning
• Suspension
• Termination of employment or engagement
• Removal from volunteer service
• Cancellation of contracts
• Recovery of financial losses
• Reporting to regulatory authorities
• Civil proceedings
• Criminal prosecution where applicable

The Foundation reserves the right to pursue all lawful remedies.

20. Training and Awareness

The Foundation may provide periodic training and awareness programs on:

• Ethical conduct
• Fraud prevention
• Corruption risks
• Financial controls
• Conflict of interest
• Reporting mechanisms
• Good governance

All associated persons are expected to familiarize themselves with this policy.

21. Policy Review

This policy will be reviewed periodically and may be updated to reflect changes in applicable laws, regulations, governance standards, or the operational needs of Ojeev Foundation.

Updated versions will be published on the Foundation’s official website.

22. Contact Information

Ojeev Foundation

Website: www.ojeev.org

Email: info@ojeev.org

Phone: +91 9220143121

Address: B3, Basement, A44, Sector 2, Noida, Uttar Pradesh – 201301

Registration Type: Section 8 Company

PAN: AAFCO1774R

DARPAN ID: UP/2026/1083277

Governing Law: Laws of India

Jurisdiction: Courts at Noida, Uttar Pradesh, India

23. Acceptance

By engaging with Ojeev Foundation as an employee, volunteer, donor, trustee, consultant, contractor, vendor, partner, beneficiary, or any other stakeholder, you acknowledge that you have read, understood, and agree to comply with this Anti-Fraud & Anti-Corruption Policy. Failure to adhere to this policy may result in disciplinary, contractual, civil, or criminal action, as appropriate under applicable law.