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Better Factories Cambodia anti-corruption statement

2 May 2018

Better Factories Cambodia (BFC) is an ILO Programme and, as such, strictly adheres to a code of conduct, a zero tolerance for fraud and high ethical standards.

ILO defines fraud and misconduct as follows;


  1. The term “fraud” is defined as “any act or omission whereby an individual or entity knowingly misrepresents or conceals a fact (a) in order to obtain an undue benefit or advantage or avoid an obligation for himself, herself, itself, or a third party, and/or (b) in such a way as to cause an individual or entity to act, or fail to act, to his, her or its detriment”.
  2. The term “presumptive fraud” is defined as “allegations that have been deemed to warrant an investigation and, if substantiated, would establish the existence of fraud resulting in loss of resources to the Organization”.
  3. The term “corrupt or collusive practices” is defined as the offering, giving, receiving or soliciting, directly or indirectly, of any advantage, in order to influence improperly the actions of another, including such conduct or arrangement between two or more bidders or contractors.


  1. In the case of staff members, the failure to comply with the ILO Staff Regulations or other relevant administrative rules and instructions or to observe the standards of conduct required of an international civil servant. Such failure could be deliberate (intentional or wilful act) or as a result of an extreme or aggravated failure to exercise the standard of care that a reasonable person would have exercised with respect to a reasonably foreseeable risk (gross negligence) or from a complete disregard of a risk where it is likely to cause harm (recklessness). In the case of non-staff personnel such service contractors and external collaborators, the failure to comply with the terms and conditions of the contract governing their relationship with the ILO.

Office of Internal Audit and Oversight

  1. The Office of Internal Audit and Oversight (IAO) of ILO has the mandate to investigate all suspected matters of fraud and misconduct by staff members. ILO conducts investigations into allegations of, amongst others, procurement fraud, corruption and bribery, theft and embezzlement, misrepresentation, misuse of ILO resources and failure to comply with financial disclosure requirements. For further information please refer to the Financial Rules and the Office of Internal Audit and Oversight’s (IAO) Investigation Charter as approved by the Governing Body.

Reporting Fraud

  1. Any case of fraud or presumptive fraud, attempted fraud, or any corruptive or collusive practices should be reported to the Director-General through the Treasurer and Financial Comptroller (Treasurer) at TRCF@ilo.org and the Chief Internal Auditor at investigations@ilo.org. The Chief Internal Auditor should also be contacted for cases of suspected misconduct.
  2. When providing the report please include as much relevant information, including attaching supporting documentation, as you are able. Typical information to include would be: a means for the investigation unit to contact you, the time and date of the alleged incident(s), the name(s) of the person(s) involved, a description of the incident, the names of any witness present (with contact information) and any other relevant information that may be of value.
  3. Rest assured that there is an obligation of confidentiality relating to information and evidence obtained during the course of an investigation.
  4. The Chief Internal Auditor and designated investigators will secure and protect all information gathered in the course of an investigation from unauthorized disclosure. However, IAO is entitled to use such information insofar as is required for the legitimate needs of the investigation or the ILO.
  5. ILO staff members have a duty to report possible incidents of fraud/misconduct as determined in the ILO Financial Rules and the Anti-fraud Policy. This duty similarly extends to third-parties pursuant to standard ILO contractual modalities.
  6. The Chief Internal Auditor will ensure that allegations are recorded, evaluated and processed in a consistent, accountable and confidential way, through a secure system. Unless the initial information was received anonymously with no means of identifying any contact details, an acknowledgement of receipt will be sent in writing to the source of a report of possible fraud / misconduct.
  7. For further information regarding the above, please refer to the regulatory texts;

The Financial Rules and the Office of Internal Audit and Oversight’s (IAO) Investigation Charter as approved by the Governing Body;

On reporting fraud, ILO’s anti-fraud policy and the financial regulations as any fraud or corruption should be reported to the Chief Internal Auditor and the Treasurer.

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