Senior Coordinator-Ethics and Compliance

Background:

The International Rescue Committee responds to the world’s worst humanitarian crises and helps people to survive and rebuild their lives. Founded in 1933 at the request of Albert Einstein, IRC offers life-saving care and life-changing assistance to refugees forced to flee from war or disaster. At work today in more than 30 countries and in 22 U.S. cities, IRC restores safety, dignity and hope to millions who are uprooted by disaster. IRC leads the way from harm to home.

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 expanding 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.

The IRC in Bangladesh has its offices in Dhaka, Cox Bazar, Ukhia and Teknaf; currently has over 400 staff and employs a further 500 incentive workers (Rohingya and Bangladeshi) to enable the frontline delivery of its programmes. Together, we aim to provide the best possible impact for some of the most vulnerable children, women and men. In all that we do, IRC strives to deliver through IRC’s core values of Integrity, Accountability, Service and Equality. This new role is at the heart of that challenge.

Job Overview/Summary:

The Senior Coordinator (Ethics and Compliance) will support the Country Director and senior staff to oversee ethics and compliance related functions across the country program. The core purpose of the role is:

To build a safe and compliant working environment within IRC, through proactive prevention initiatives to reduce wrongdoing and timely, coordinated action where behavior is suspected to be inconsistent with IRC values and policies.

The role will have a range of responsibilities, all aimed to promote ethics and compliance in the behavior of staff and incentive workers and to coordinate consistent and effective follow up as needed  when there are allegations of misconduct. 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.

Broadly, the role covers:

Prevention:

Working across stakeholders to promote a culture that adheres to IRC values and is fully compliant with our policies, procedures and the law. This includes developing an appropriate control environment and ensuring standard operating procedures and IRC policies are followed. Where weaknesses in controls or their application are identified, the Senior Coordinator (Ethics and Compliance) will recommend appropriate actions in consultation with relevant stakeholders and will also ensure appropriate reporting to responsible parties (including HR, Finance, Supply Chain, ECU, Senior Programme Coordinator and the CD) to ensure central support remediation. 

Promote a culture of ethics and compliance with a strong understanding of IRC’s Code of Conduct and Values. Work with others such as the IRC’s global Ethics and Compliance Unit (ECU) to support training and communications on issues including fraud and corruption and safeguarding (exploitation and sexual harassment and violence against staff and clients). Participate in and share best practices with the Compliance Coordinator Group.

Promote an expectation and culture of reporting suspected misconduct into the ECU for any suspected forms of abuse or wrongdoing, to allow for proper follow-on and action as required.

Develop and manage aspects of the country program’s compliance process, relating to ethics and compliance, to include fraud, corruption, safeguarding and sexual harassment and exploitation or violence.

Response: Misconduct Allegations and Investigations

The Senior Coordinator (Ethics and Compliance) will work with IRC’s global Ethics and Compliance Unit (ECU), to ensure that the local staff and partners are aware of the IRC’s reporting mechanisms; and shall support the ECU on investigations in accordance with the IRC’s investigation’s process.

The Senior Coordinator (Ethics and Compliance) will report to the Country Director (CD), and, in the cases of investigations, to the Ethics and Compliance Unit’s Senior Director of Investigations (SDI). The position will update the country director on allegations as agreed with ECU on a case by case basis. In conjunction with ECU, the position will inform the Regional Vice-President Asia of any allegations that impact on the Country Director.

Major Responsibilities:

Prevention: Create a safe and compliant environment

·Support the development and monitoring of a country level risk report card including identification of appropriate actions for ethics and compliance related concerns.

·In coordination with and under the guidance and direction of the Country Director and the Global Ethics and Compliance Unit, act as focal point for IRC- ECU policies

·Coordinate a training and awareness programme for all staff and partners on ethics and compliance issues. Work with many stakeholders (HR, gender champions, finance, supply chain and organizational leadership) to roll-out policies and initiatives and consistently refresh training provided.

·Actively monitor the status of mitigation measures as they pertain to compliance requirements and in accordance with the IRC Enterprise Risk Management approach.

·Coordinate and conduct ethics and compliance reviews of IRC, partner and sub-partner activities to assess adequacy and effectiveness of internal controls and compliance. Aim to build the capacity of partners wherever possible

·Using a range of innovative strategies to promote a culture of ethical and compliant behaviours across all sites

·Support the development or adaptation of policies designed to create a safer working environment

·Promote a culture of reporting on ethics and compliance concerns, providing appropriate feedback to staff, partners and complainants, working closely to ensure support and follow up is provided.

·Produce consolidated internal reports (ethics and compliance) with findings and issues identified during these reviews, provide appropriate recommendations on improvements to the country program and related partners’ processes, systems and procedures where appropriate.

·Work with Safeguarding focal point(s), HR and local staff to ensure implementation of IRC’s global safeguarding strategy addressing prevention of and response to Safeguarding misconduct.

Misconduct Allegations and Investigations

·The Senior Coordinator (Ethics and Compliance) will work with IRC’s global Ethics and Compliance Unit and Country leadership, to ensure that staff and partners are aware of the IRC’s reporting mechanisms;

·Provide timely support to the ECU on investigations as appropriate, in accordance with the IRC’s investigations process.

·Contribute to investigations on a case by case basis under the guidance of ECU (Sr Director of Investigations).  This may include the below:

oBy agreement and in conjunction with ECU, support or undertake investigations of breaches of IRC Way including alleged fraud, waste, financial corruption and safeguarding misconduct while  ensuring objectivity, impartiality and fairness throughout the investigative processes in accordance with generally recognized international investigative standards, and IRC Investigation Guidelines;

oPrepare investigation reports (in English) and ad hoc briefs pertaining to investigations in coordination with ECU;

oLiaise with ECU to ensure identification of impacted donors on allegations of misconduct;

oUndertake investigation assignments in the local area at the direction, and in coordination, with ECU, keeping country and regional management informed, when appropriate, consistent with any investigation confidentiality constraints

oRegularly exchange with regional HR to get updates and assess progress on any Employee relation cases assigned to HR.

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

Other

·Conduct any ad-hoc internal investigative/ crisis related assignments as requested by ECU, the Country Director and in coordination with ECU or HR or in response to donor specific queries.

·Work in collaboration with and support MEAL Coordinator on client responsiveness.

·Assess compliance related risk and manage the resolution of clients’ feedbacks and complaints in confidential manner, within given timescales. Escalate 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.