Anti-fraud and anti-corruption policy.

Purpose and scope

This policy sets out how Asociația Grupul Verde prevents, detects and deals with fraud, corruption and any misuse of resources. It applies to board members, staff, volunteers, contractors, suppliers and partners who handle money or assets in our projects.

What we mean by fraud and corruption

• Fraud: any intentional act or omission to obtain an undue advantage — false documents, fictitious or inflated costs, inaccurate statements to funders.
• Corruption: offering, requesting or accepting, directly or indirectly, an advantage to influence a decision.
• Misappropriation: using money or assets for a purpose other than the one they were granted for.
• Double funding: claiming the same cost from two sources.
• Money laundering and financing illegal activities, including through donations.

Financial controls

• Four-eyes principle: every payment has at least two approvals, and whoever orders is not the one who approves the payment.
• Payments are made by bank transfer; cash payments are the exception, justified and documented.
• Each project has its own budget and accounting records, so every cost can be traced to its supporting document.
• Documents are archived for at least the period required by law and by the grant agreement.
• Assets bought with project funds are inventoried and used only for the project.

Donations and sponsorship

• We accept donations and sponsorship only from legal sources compatible with our mission.
• We verify donors’ and sponsors’ identity where the law requires it and decline support that raises money-laundering concerns or conflicts with our values.
• We use every donation for the purpose the donor chose and report how it was used.

Partners and suppliers

• We ask partners and suppliers to follow these principles; contracts include anti-fraud clauses and our and the funder’s right to inspect documents.
• We do not work with organisations or people on EU sanctions lists.

How to report

If you suspect fraud, corruption or misuse of funds:

• write to office@grupulverde.ro with the subject “Confidential report”, or call +40 374 962 748 — the report reaches Marian Dumitru; if it concerns him, write to the Chair of the Board at the same address, marked “For the attention of the Board”;
• you can also report directly to the project funder, the European Anti-Fraud Office (OLAF), Romania’s Fight Against Fraud Department (DLAF) or the National Anticorruption Directorate (DNA).

Reports can be anonymous. Good-faith reporters are protected from any retaliation, in the spirit of Romanian Law 361/2022 on whistleblower protection.

What happens after a report

• The report is recorded and checked confidentially by people not involved in the matter reported.
• We inform the funder within the deadlines in the grant agreement and refer the case to the competent authorities when there are signs of an offence.
• We recover misused funds and apply disciplinary or contractual measures.
• We fix our procedures so the situation does not happen again.

Responsibilities

• The Board adopts the policy, approves financial procedures and receives an annual report on reports received.
• The focal point — Marian Dumitru — receives reports, keeps the confidential register and trains the team.
• Every team member follows the procedures and flags any suspicion.

Adoption and review

This policy was adopted by the Board of Asociația Grupul Verde on 16 October 2026 and is reviewed every year. Version 1.0 · in force from 16 October 2026.

Legal basis and standards

Our other policies:

• Child safeguarding
• Conflict of interest
• Privacy and GDPR