Head of Ethics, Compliance and Accountability

Job Title:

Head of Ethics, Compliance and Accountability

Department/ Program:

Country Program

Work Location:

IRC-Bangladesh, Dhaka Office

Line Manager:

Country Director

Grade:

6A

Contract Length:

1 Year

Program Brief

Founded in 1933, International Rescue Committee (IRC) is one of the world’s leading agencies working in post-conflict and development contexts, supporting communities in over 40 fragile, failed and developing states. In this capacity, we work to restore safety, dignity and hope to millions who are uprooted, struggling to endure and wishing to advance on a path of development.

IRC has been present in Bangladesh since 2017 and obtained registration with the NGOAB in March 2018. Since IRC obtained registration in March 2018, it has moved quickly to expand its integrated emergency health and protection response through both direct and partner-based programming focused on primary healthcare, women’s protection and empowerment, sexual and reproductive health, gender-based violence and child protection. Through 2018, the IRC’s response strategy will primarily target Rohingya refugees in Cox’s Bazar, while meeting the significant needs in both refugee and host populations, as already existing vulnerabilities are compounded with cyclical monsoon and cyclone seasons that impose additional threats to the lives and protection of those refugees as well as vulnerable host populations. IRC is growing its programming to cover education and livelihoods/DRR, as well as its geographic foot print in the host community and to other parts of the country.

Purpose of the Role

The Head of Ethics, Compliance and Accountability will support the Country Director (CD) to oversee internal controls and compliance functions across the country program including support to ensure that sub-grantee/partners are compliant with IRC’s and its donors’ rules and regulation. The position holder will work with staff to create a culture reflecting the high ethical standards of IRC. (S)He will work with all SMT, CMT, regional HR and country program to ensure an effective, efficient, ethical and functional feedback and complaint response mechanism is in place and that the organizational functions are in compliance with IRC policies.

If an allegation of financial integrity, non-Employee Relation cases, the position holder will report the matter to IRC’s global Ethics and Compliance Unit (ECU) in consultation with CD if appropriate and keep CD fully informed. In the case of such investigation, ECU will partner with the position holder to provide clarity of roles in the investigation on a case by case basis. This could include providing documentation, access, or if so directed, conducting the investigation under ECU’s guidance and according to ECU’s standards and protocols. (S)He will be directed by the ECU but will keep country management fully informed unless country management is implicated and confidentiality concerns call for non-disclosure of information pertaining to the investigation to the country leadership. In such a case, the Regional Vice President Asia will be kept fully informed.

The post holder will also act as IRC Bangladesh’s Chief Anti Money Laundering Compliance Officer – (CAMLCO) as per instructions of Bangladesh Bank and NGO Affairs Bureau, GoB.

Highlights of Key Responsibilities

1.Internal Controls and Compliance:

• Facilitate program, operations and partners in compliance risk analysis, adopt IRC’s risk framework and proactively coordinate use of risk register and corrective actions with program and operations.
• Coordinate and conduct compliance, operational and financial reviews of IRC partners and sub-partners (operation & program) to assess adequacy and effectiveness of internal controls, risk management and compliance to policies, procedures and regulations.
• Produce consolidated internal reports (compliance, operational and financial) with findings and issues identified during these reviews, give appropriate recommendations on improvements to the country program and related partners’ processes, systems and procedures where appropriate.
• Conduct any ad-hoc internal audit assignments as requested by the Country Director/RHRD/Regional Finance Controller or RVP Asia or in response to donor specific queries.
• Stay informed of and ensure adherence to IRC and donor procedures and policies in relation to Supply Chain, Finance, HR and Programs as set out in relevant IRC/Donor manuals and guidelines.
• Assist Country Director in collaboration with AMU on large contracts and MoUs, service agreements, teaming agreements and other contractual agreements prior to signing.

2.Misconduct Allegations and Investigations:

• Contribute to investigations on a case by case basis under the guidance of the CD/RHRD/RVP and ECU depending on nature of cases. This may include the below:
• Undertake investigations of alleged fraud, waste, financial corruption, misconduct, ensuring objectivity, impartiality and fairness throughout investigative processes in accordance with generally recognized international investigative standards and IRC guidelines.
• Prepare reports and ad hoc briefs pertaining to investigations in coordination with the ECU.
• Undertake investigation assignments in the local area at the direction, and in coordination, with ECU, keeping country and regional management fully informed consistent with any investigation confidentiality constraints.

3.GoB Compliances Related to Anti Money Laundering and Others:

• Act as Chief Anti Money Laundering Compliance Officer – (CAMLCO) as per instructions of Bangladesh Bank and NGO Affairs Bureau, GoB.
• Ensure IRC’s full adherence to GoB guidelines on Prevention of Money Laundering and Terrorist Financing for NGO/NPO Sector and relevant reporting requirements.
• Work closely with relevant team members to support and ensure IRC’s adherence to GoB’s rules and regulations for INGOs in Bangladesh.

4.Training:

• Act as focal point for IRC- ECU and donor fraud and anti-corruption policies and lead effective communication and training of these policies to staff.
• Support training and workshops to IRC staff and partners in collaboration with ECU and HR on ethics and compliance, in particular the IRC Code of Conduct.

5.Client Accountability:

• Using standard tools and methods, communicate and ensure all beneficiary/client feedbacks and complaints are acknowledged in a timely manner and clients are kept informed throughout the process in collaboration with country MEAL Coordinator.
• Assess risks and manage the resolution of clients’ feedbacks and complaints in confidential manner, within given timescales.
• Raise issues from local client responsiveness mechanisms to CD/ECU when appropriate. Ensure local accountability staff are trained in what to escalate and how to do so.
• Facilitate teams to develop standards for beneficiary/client Feedback and Complaint Response Mechanism (FCRM) to integrate into program and operational activities and ensure the placement of these standards in the form of banners/posters at common places.
• Work closely with global and regional client responsiveness, and accountability staff to strengthen the system in Bangladesh and improve coordination and communication flow.
• Manage client response system according to guidelines and procedures in consultation with client responsiveness and accountability staff.
• Train staff on accountability, GoB’s relevant framework for INGOs, enable them to sensitize the communities to use their right of feedback, complaints and collect real time feedback/complaints when needed and investigate complaints.
• Generating feedback and complaint analysis and reports for management use regularly.
• Perform other tasks as requested by the management from time to time.

Key Working Relationships

• Position reports to:
• Country Director

·Position directly supervises:

• N/A

·Other internal and/or external contacts:

• Internal: Country SMT, Regional Vice President Asia, Regional Supply Chain, Regional Finance and HR Directors, HQ based ECU
• External: Legal Counsel, Consultants, Vendors, Suppliers, Partner NGOs, People in Communities