Nuffic’s integrity policy

Nuffic’s ambition is for all pupils and students to have the opportunity to acquire international competences, whether at home or abroad. This will prepare them for the society and labour market of the future and ensure that they are ready to tackle the global challenges of our time. After all, international problems require international solutions. Economic, political or social tensions do not stop at national borders.

Nuffic’s core values are:

• Connecting: we bring people, languages and cultures together to ensure that everyone can gain international experience.
• Inspiring: we are committed and expert. Whatever we know, we want to share. By doing so, we inspire others.
• Accessible: we are there for everyone and we view the world with an open attitude.

Our ambition and core values mean that social impact and themes such as sustainability and diversity run through the veins of our organisation. An integral part of this is a desire to act with integrity, a desire to do the right thing.

Nuffic cannot fulfil its ambition without behaving in an open and honest manner towards donors, students, partner organisations, researchers, the government, educational institutions and of course our own employees: the entire community in which we operate. We see it as our responsibility to do this, but it is also our intrinsic desire to behave in this way. That is why we have drawn up this integrity policy, to formalise our intrinsic desire to do the right thing. This policy describes what acting with integrity means to Nuffic, the times at which Nuffic as an organisation and its employees are most vulnerable, and our response.

This integrity policy consists of the following parts:

1. Vulnerabilities in work processes
2. Policy statement
3. Our integrity policy
a. Prevention
b. Raising awareness and detection
c. Reporting and follow-up
d. Accountability
4. Other guiding principles
5. Definitions

Nuffic recognises that its tasks and activities may give rise to the following vulnerabilities in terms of integrity:

• Nuffic operates in an environment where unequal power dynamics between, for example, teachers and students/pupils or Nuffic and those receiving funding can occur.
• Nuffic’s activities indirectly serve children, young people and students, who are particularly vulnerable to abuse of any kind.
• Nuffic has tasks and performs activities that benefit individuals (for example students and teachers) who, by making use of these services, can find themselves outside their own familiar environment. This includes both foreign individuals in the Netherlands and Dutch individuals abroad. This group is particularly vulnerable to abuse because they are outside their social environment and may be less familiar with local social norms.
• As Nuffic operates in a chain, we can only work on integrity and protecting the individuals working at, with, for or on behalf of Nuffic in collaboration with our chain partners.

This integrity policywill help to ensure the general integrity of our organisation and specifically addresses these vulnerabilities.

We aim to give every pupil and student an international experience. To do this, we work in a chain with educational institutions in the Netherlands and abroad, umbrella organisations, partner organisations, and government organisations in the Netherlands and other countries.

We are aware that integrity violations are often based on a conscious or unconscious power imbalance and relationship of dependence such as between subsidy provider and subsidy recipients, between a teacher and a student, but also at our office for example between a team lead and an employee.

This power imbalance and relationship of dependence can create the conditions and lower the threshold for individuals to abuse their position. Because others do not dare to contradict them, or because the boundaries between what is and what is not acceptable are blurred.
As a result, certain individuals or groups may in practice receive privileges relative to others.

To make sure that everyone (who works at, with, for and on behalf of Nuffic) feels safe and respected (both physically and digitally) a Code of Conduct was established that provides guidelines for acting with integrity. A Code of Conduct cannot list everything that is or is not allowed, but what it can do is describe our commitment to a safe workplace through examples. Below, the four categories of integrity violations are described and the Code of Conduct explains what behaviours contribute to a safe work environment.

Interpersonal violations
Nuffic aims to create a safe environment for our everyone who works at, with, for and on behalf of Nuffic. All employees have a duty to comply with the principles of this policy. They commit to safeguarding a work culture dedicated to creating that safe environment. Nuffic considers violence, (sexual) exploitation and abuse by employees (including the people who work for, with or on behalf of Nuffic) as serious offences and cause to take disciplinary measures. The precise nature of these measures depends on the circumstances. Together, we are committed to respectful collaboration and a safe working environment, enabling everyone to deliver their best work and grow personally.

Financial violations
We strive to build relationships with suppliers, partner organisations, governments, public officials, politicians and other stakeholders that are based on professionalism, trust and integrity. We will never make illegal payments, do or request illegal favours or engage in other acts that could expose Nuffic to risks of financial loss, dependence, blackmail, extortion, financial penalties and reputational damage. We operate a ‘zero-tolerance’ policy towards all forms of fraud and corruption.

Information security & privacy violations
By handling information with care, we protect our organization, colleagues, and partners. We ensure that we treat information from Nuffic and its partners to protect confidentiality, integrity and availability of information. All employees are obliged to adhere to the principles and policy frameworks in the domain of information security and privacy and to follow instructions in this regard. The policies on information security are internal documents.

Abuse of power and conflicts of interest
By acting with integrity and transparency, we are credible and able to make independent decisions. Nuffic and everyone who works at, with or for Nuffic base their actions on the following norms and values to prevent abuse of power:

• Respectful
  Everyone is treated with respect and there is no discrimination. However, if an employee observes disrespectful behaviour the matter is discussed and reported (through the channels described below). This applies to all forms of disrespect, such as discrimination, exploitation, intimidation or abuse. Special attention is given to children and young people given their vulnerability.
• Professional and independent
  In our activities, it is important that our relationships with all parties are independent and objective. Personal interests are avoided, and where personal interests exist they are reported and kept strictly separate from business interests. All conflicts of interest or the appearance thereof are avoided. This includes financial integrity and dealing with material matters. Nuffic is honest and transparent in such dealings, and is therefore always able to explain why certain decisions have been taken.
• Reliable, honest and transparent
  Nuffic is a reliable partner, meaning that employees live up to expectations and communicate honestly. We do not make commitments that we may not be able to or are not able to keep, and we do not set unrealistic expectations in our communication. We fulfil our agreements. Laws, rules, standards for things such as quality, and norms, social and otherwise, are adhered to, both in letter and spirit. Nuffic and its employees work as transparently as possible, are accountable and take responsibility in this respect.
• Careful
  We make decisions carefully, with thorough consideration of the various interests involved. We use public funds and other resources in a targeted and cost-effective manner. Employees also use office and ICT facilities provided by Nuffic in a responsible and professional manner. This applies in particular to use of the internet, email and social media. We handle personal and other data confidentially.

Nuffic is responsible for creating a socially safe environment in which integrity issues can be discussed and to promote awareness of what acting with integrity involves. Nuffic aims to ensure an environment in which (1) deliberate unacceptable behaviour is tackled, but also in which (2) we become more aware of unwitting, well-intentioned behaviour that can have negative consequences. For this reason, the integrity policy is made up of the following components

1. Prevention
2. Raising awareness and detection
3. Reporting and follow-up
4. Accountability

3.1 Prevention
Prevention starts with a clear code of conduct, which serves as a guide for everyone who works at, for or with Nuffic. This code of conduct is integrated into contracts and decisions, to ensure that partners also adhere to Nuffic’s integrity standards. The code of conduct can be viewed online.

3.2 Raising awareness and detection
The policy and code of conduct must be embedded in the things we do (our activities and work processes) and the manner in which these things are conducted (i.e. our behaviour). For example, appropriate activities are undertaken for various groups:

Employees

• Employees (internal and external) explicitly sign the Nuffic Code of Conduct and the regulations on responsible use of email, the internet and ICT resources.
• All external employees and certain internal job groups are also required to obtain a Certificate of Conduct (VOG). Being able to present a VOG is a dissolving condition in the contract for these employees.
• Integrity is an important part of our recruitment policy. The importance of integrity is always explicitly mentioned in job postings, discussed during interviews, and selection committees are informed about unconscious bias. Before hiring a new employee, we always conduct reference checks, including a specific question about integrity violations (if the response is negative, the candidate will not be hired)."
• Integrity refresher training is organised for employees every year.
• This training is included in the induction programme for new employees.
• Employees participate in an introductory training on information security and privacy, as well as activities related to awareness on these topics.

Partners

Nuffic’s values are promoted and the importance of acting with integrity features on the agenda of full-day workshops, partner days, the Nuffic Conference and policy consultations with clients.

3.3 Reporting and follow-up
There are a number of ways to report undesirable behaviour, (suspected) integrity violations andmisconduct and to conduct an investigation into possible infringements of the policy and code of conduct, both internally and externally. These are described in the staff handbook.

To report undesirable behaviour, (suspected) integrity violations and misconduct, the online form can be used. This form can be used internally and externally.

Additionally, for some programs potential integrity violations must be reported. It varies per program and client how this should be done.

To ensure the integrity policy is embedded within the Nuffic, an ‘Integrity Coordinator’ is appointed in each cluster and the BBD. Their responsibilities include:

• Serving as a point of contact for integrity-related issues
• Receiving reported integrity violations
• Coordinating the follow-up of these reports
• Acting in an advisory and signaling role towards the board
• Organizing a annual evaluation of the integrity policy
• Reporting (see Article 3.4)

3.4 Accountability
Reports and how they are handled must be recorded and reported. The issue of integrity must also be included as a policy topic in the annual report and discussed in the annual policy consultations with the client.

This means the following:

1. Integrity is a shared responsibility of all employees and the organisation as a whole. That is why there are no designated individuals or teams responsible for the integrity of the organisation.
2. As owners of the work processes and content, the team leaders are financially and personally responsible for safeguarding integrity in the work processes and raising awareness among employees.
3. HR is responsible for the accuracy of information about the integrity policy (both internally on Next and externally on the Nuffic website) and for facilitating the annual integrity training.
4. The Dutch language prevails for the integrity policy and its annexes, since these documents were developed in Dutch. The documents have been translated into English.

• Reporter: Someone who, in the context of their work-related activities, reports undesirable behavior, integrity violations, or a (suspected) wrongdoing.
• Integrity violation: An act or omission that breaches Nuffic’s rules, norms, and values. Four categories are distinguished: interpersonal violations, financial violations, information security and privacy breaches, abuse of power, and conflicts of interest.
• Undesirable behavior: Behavior that others experience as unpleasant, threatening, humiliating, or intimidating.
• Reporting procedure: The way in which (internally or externally) a report can be made regarding undesirable behavior, integrity violations, or a (suspected) wrongdoing.
• (Suspected) wrongdoing (whistleblower policy):
  • A breach of or threat to EU law
  • An act or omission that affects the public interest, such as a risk of violating a legal provision or internal rules that impose a concrete obligation on Nuffic, public health, personal safety, the environment, or the functioning of public services
  • The act or omission does not only affect personal interests and is part of a pattern, has a structural nature, or is serious and extensive.