Our commitment to ethics, compliance and safeguarding
As a global organization active in more than 60 countries around the world, we are committed to conducting our work ethically and promoting safe, supportive and respectful work and program environments. We take seriously our promise to implement policies and practices that prevent fraud, waste, abuse and misconduct and to protect anyone and everyone who engages with our organization and programs — participants, partners, funders and team members.
The policies below set forth our standards of ethical behavior and expectations for professional conduct. These policies provide clear directions to achieve our vision and mission and live our values according to the highest standards. Through training and systematic reviews, our Office of Compliance and Internal Audit (OCIA) works with management to ensure our team members have the information and understanding they need to maintain these standards and to promote a culture of compliance and personal responsibility. At FHI 360, compliance is everyone’s responsibility.
For additional information or questions about FHI 360’s efforts to prevent and respond to instances of fraud, waste, abuse or misconduct, please contact compliance@fhi360.org.
Need to report an incident or concern? Use our ethics and compliance hotline at any time and report anonymously if preferred.
Our approach to preventing fraud, waste, and abuse of resources
We hold ourselves, our team members and our implementing partners accountable for attaining program objectives and responsibly expending funds in service of our program participants with the utmost integrity. Regular monitoring, internal audit reviews, and compliance training are part of overall oversight in ensuring funds entrusted to FHI 360 are used as intended.
OCIA delivers independent, objective assurance and consulting services to enhance FHI 360’s global operations. While maintaining its independence and objectivity, OCIA collaborates with our team members and partners to ensure efficient resource acquisition, effective resource utilization, and adequate protection. By continuously enhancing and maintaining robust internal controls and safeguarding mechanisms, FHI 360 teams adhere to relevant policies, procedures, laws, regulations and funder requirements.
Our approach to safeguarding
Safeguarding encompasses the systems and practices that organizations have in place to prevent harm to people — especially children, young people and adults who are vulnerable to exploitation and other abuse — while conducting development work and providing humanitarian assistance. At FHI 360, safeguarding includes:
- Designing and delivering safe programs that do not put program participants or personnel at risk of being harmed.
- Protecting our staff from any type of harm, including sexual abuse, exploitation and harassment.
- Protecting program participants from any type of harm that happens during and/or because of their engagement with our organization or programs, including sexual exploitation and abuse, child abuse, and human trafficking committed by our own personnel or partner personnel.
FHI 360’s framework for safeguarding program participants includes a set of minimum standards, which are required actions for all projects that involve interaction with program participants. These standards align with our policies, international standards, InterAction’s CEO Pledge (which is signed by FHI 360’s chief executive officer), the Common Approach to Protection from Sexual Exploitation, Sexual Abuse, and Sexual Harassment (CAPSEAH), which FHI 360 has endorsed, and major funder requirements. When effectively and fully implemented, the minimum standards mitigate risks of harm and help us respond effectively if harm does occur. FHI 360’s Safeguarding and Program Support Department includes dedicated staff to support the integration of these standards across the organization and ensure the uniform application of FHI 360’s safeguarding policies.
Safer recruitment and hiring
To further strengthen our safeguarding practices, FHI 360 joined a growing number of organizations in the development sector as a member of the Misconduct Disclosure Scheme (MDS). The goal of the MDS is to stop perpetrators of sexual misconduct from moving between organizations undetected. It provides a channel for humanitarian and development organizations to request and share information about employment candidates to determine whether they have substantiated histories of sexual misconduct with prior organizations. This information enables organizations to make informed recruiting and hiring decisions and protect others from potential harm.
How to report an incident or concern
Our 24-hour ethics and compliance hotline is accessible worldwide and managed by an independent third-party provider. It can be used to report an incident or concern at any time. The hotline allows you to report in your preferred language and anonymously. You can access the hotline here.
Our country offices and project teams also establish project-level safeguarding reporting mechanisms, where needed, to ensure program participants have safe, accessible and trusted ways to report harm. When reports are received at the project-level, the teams are required to promptly report the incidents to OCIA to ensure effective and timely investigations into the incidents.
OCIA is led by the chief compliance officer, who reports to the Audit Committee of FHI 360’s board of directors — an independent reporting structure that ensures unbiased review, accountability and oversight.
Our response to incident reports
All allegations of fraud, waste and abuse of resources, and sexual exploitation and abuse are received and investigated. Depending on the issue, professionals with internationally recognized accreditations — including certified internal auditors and certified fraud examiners — and human resource professionals are assigned to conduct investigations.
In responding to reports of safeguarding concerns, FHI 360 takes a survivor-centered approach. This means we prioritize the dignity, rights and safety of victims and survivors. This includes ensuring that victims and survivors have access to information and resources, including referrals to health services, legal assistance and psychosocial support according to individuals’ wants and needs. Our country teams are tasked with understanding local resources and connecting individuals to those resources where and when they are available. In addition, where there are barriers to or a lack of resources, our teams work closely with leadership to ensure that victims and survivors still receive the support they need, according to their wishes.
We will hold accountable FHI 360 personnel or partner personnel who engage in any harmful behavior, including fraud, waste, abuse, corruption, discrimination, exploitation, harassment and violence. We will also protect from any form of retaliation those who report suspected or known harm. Retaliating against someone for reporting or participating in an investigation violates FHI 360 policy. Individuals who participate in retaliation are subject to disciplinary action, including termination of employment or other relationship with FHI 360.
Safeguarding support to local organizations
FHI 360 shares our technical knowledge and experience to help local organizations:
- Develop safeguarding policies.
- Establish an approach for identifying safeguarding focal points.
- Strengthen protocols for safe recruitment and hiring.
- Extend safeguarding requirements to their own partners.
- Implement mandatory training during onboarding of new staff.
- Establish internal reporting mechanisms.
- Raise awareness among program participants about how to report harm.
- Develop protocols for responding to complaints.
Annual safeguarding-related incident reports
FHI 360 publishes an annual safeguarding-related incident report, which includes information about the number and types of safeguarding-related complaints, investigations and outcomes. The report aligns with our commitment to be transparent with key stakeholders, including the communities where we work.
Below are our annual safeguarding-related incident reports:
2023 Safeguarding-Related Incident Report [Arabic, French, Portuguese, Spanish]
Our policies and supplemental guidance
Business integrity: Dealing with governments or officials; compliance with the Foreign Corrupt Practices Act
Combating human trafficking
Download: FHI 360 Policy on Combating Trafficking in Persons (Arabic) (French) (Portuguese) (Spanish) (Ukrainian)
Download: FHI 360 Universal Safeguarding and Anti-Trafficking Compliance Plan (Arabic) (French) (Portuguese) (Spanish) (Ukrainian)
Download: FHI 360’s Anti-Trafficking and Modern Day Slavery Statement
Harassment-free work environment
Download: FHI 360 Policy on Harassment-Free Work Environment (Arabic) (French) (Portuguese) (Spanish) (Ukrainian)
Protecting program participants from sexual exploitation and abuse
Safeguarding of children
Download: FHI 360 Policy on Safeguarding of Children (Arabic) (French) (Portuguese) (Spanish) (Ukrainian)
Standards for research involving human subjects
Research integrity and conflict of interest
Research integrity and misconduct
Violence-free work environment
Download: FHI 360 Policy on Violence-Free Work Environment (Arabic) (French) (Portuguese) (Spanish) (Ukrainian)
