Complaints procedure

Procedure on reporting fraud, corruption and integrity violations to Milieudefensie. Annex to 'Milieudefensie policy on integrity and preventing fraud, corruption and non-compliance in collaboration with partner organisations'

Milieudefensie cooperates with other organisations, communities and individuals in the Netherlands and abroad on environmental and social issues. This cooperation may involve financial support. Milieudefensie needs to ensure that its support reaches these organisations in the most efficient, effective and transparent manner possible and that the support is used for the purposes it is meant for.

There is no room for fraud and corruption, which would divert support and resources elsewhere. Also Milieudefensie doesn't accept other integrity violations such as inappropriate behaviour. Milieudefensie will always act upon reports of (imminent) fraud, corruption and other integrity violations. The organisation will always research the case and if the allegations are substantiated, always apply appropriate sanctions.

Milieudefensie adopted a 'Policy on integrity and preventing fraud, corruption and non-compliance in collaboration with partner organisations'. The policy's goal is to prevent fraud and corruption in Milieudefensie-supported programmes and projects, as well as in connection to contracts, terms of reference (ToRs), memorandums of understanding (MoUs) and other agreements. Copies of the policy can be requested at servicelijn@milieudefensie.nl.

What is considered fraud or corruption?

Fraud and corruption include, but are not limited to:

• Corrupt practice - offering, giving, receiving, or soliciting, directly or indirectly, anything of value to influence improperly the actions of another party;
• Fraudulent practice - any act or omission, including a misrepresentation, that knowingly or recklessly misleads, or attempts to mislead, a party to obtain a financial or other benefit or to avoid an obligation;
• Collusive practice - an arrangement between two or more parties designed to achieve an improper purpose, including influencing improperly the actions of another party;
• Coercive practice - 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.

What is considered integrity violation and inappropriate behaviour?

Integrity violation and inappropriate behaviour include, but are not limited to:

• Bullying, harassment, intimidation, verbal and physical aggression and violence, unwanted intimacy, discrimination and exclusion;
• Spilling financial means and theft;
• Sharing information that is classified by Milieudefensie or the partner as confidential information;
• Actions that would harm public health, safety and the environment;
• All other forms of inappropriate behaviour (including inappropriate sexual behaviour);
• Intentionally witholding, destroying or manipulating information about facts related to all types of integrity violations (including fraud and corruption and non-compliance with agreements).

How to report a (presumed) case of fraud or corruption

You can submit your complaint by email, telephone or letter to:
Milieudefensie,
attn. the Director
Postbus 19199
1000 GD Amsterdam
servicelijn@milieudefensie.nl
+31-20-5507300

If the case concerns the director, you can submit your complaint to Milieudefensie's internal or extrenal trust person. Ask for the trust person's contact details at servicelijn@milieudefensie.nl.

Please send us:

• a brief and clear description of the (presumed) case of fraud, corruption or integrity violation;
• the names of the organisation(s) and/or person(s) (staff) involved;
• your name and address (we will treat your data with the utmost confidentiality);
• your signature and date of signature (in the case of information sent by letter);
• an (email)address and telephone number where we can reach you.

Try to be as clear and complete as possible in describing the case and the grounds on which it is based. This will help us deal with it as quickly as we can.

Processing and registration of fraud and corruption cases

Your information will be directly forwarded to the director. The person handling your case will confirm receipt as quickly as possible and no later than two weeks after the case has been received. Your case will be registered by Milieudefensie. Your personal data will be dealt with in the strictest confidence.

The director decides how the case should be handled. If you indicate this interest, we will inform you in writing of the results of the inquiry, the decision taken and any conclusions attached to the decision.

If the case concerns the director, the internal or external trust person to whom you've reported will decide how the case will be handled.

Milieudefensie takes all possible actions to protect from reprisals whistleblowers, individuals who submit allegations of fraud and corruption or inappropriate behaviour in its activities and operations, individuals who help reveal fraud and corruption or inappropriate behaviour in its programmes, project or grant activities, as well as individuals subject to unfair or malicious allegations.

If needed, relevant donor agencies and other working partners will be informed in case presumed fraud or corruption has been proven.