Code of conduct for integrity

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1. Scope

This Code of Conduct applies to all components of Nuffic, including:

  • The activities carried out by the Nuffic office in the Netherlands.
  • The projects, events and other activities organised by Nuffic in the Netherlands.
  • The activities of the Nuffic offices abroad.
  • The tasks and projects carried out abroad on behalf of Nuffic, including if these are carried out by subsidy recipients and beneficiaries with Nuffic funding.

The Code of Conduct covers the following types of unacceptable behaviour:

  • Interpersonal misconduct:
    sexual harassment, intimidation and violence; aggression, discrimination and bullying;
  • Financial misconduct:
    fraud; improper use/misuse of funds; theft; tax evasion and asset management/investment policy contrary to organisational objectives;
  • Abuses of power:
    corruption; conflicts of interest and nepotism; manipulation or misuse/leaking of information.

2. Objective

Beneficiaries of Nuffic’s activities often only indirectly have contact with Nuffic. Nuffic often has no direct relationship, contractual or otherwise, with the target group. Nevertheless, Nuffic believes it can contribute to creating a safe setting for this international environment.

The objective of this policy is to guarantee that:

  • all people who work for us, with us and on our behalf possess the necessary competences, self-confidence, understanding and support to fulfil their responsibilities in protecting our target group against violence, in preventing fraud and corruption and in combating abuses of power;
  • we follow the necessary procedures to prevent and monitor actions and behaviour of our employees, individuals who work with or on behalf of Nuffic, and subsidy recipients and beneficiaries that could result in violence against someone in our target group, fraud, corruption or abuses of power;
  • the target group we work with is aware of our duty to prevent any injustice that may be inflicted on them as a result of the actions and behaviour of our employees, people who work with or on behalf of Nuffic and subsidy recipients and beneficiaries, as well as our duty to respond to injustice that does occur;
  • our target group is aware of the available channels to report these types of incidents;
  • we make the right agreements with our partner organisations (subsidy recipients, beneficiaries and suppliers) on declaring this Code of Conduct applicable to at least the activities carried out in the context of contractual obligations between Nuffic and the relevant partner organisation.

Policy statement

Our aim is for every pupil and student to gain international experience. To achieve this, we work in a chain along with educational institutions in the Netherlands and abroad, umbrella organisations, subsidy recipients and beneficiaries in developing countries, and government organisations in the Netherlands and abroad.

We realise that integrity violations are often based on a conscious or unconscious imbalance of power, such as between subsidy provider and subsidy recipient, between ‘the West’ and developing countries, or between teacher and student.

This power imbalance creates the conditions and reduces barriers for people to abuse their position. This can be because others are afraid to speak out against them or because the line between what is and is not allowed becomes blurred. In practice, the result is that certain people or groups receive exclusive privileges. A power imbalance in turn leads to more inequality and possibilities for abuses of power.

The key to an effective integrity policy therefore lies in raising awareness about such imbalances of power and the safety risks they entail for everyone who works at, with, for and on behalf of Nuffic, so that we can engage in more equal collaboration.

Protection

Nuffic is dedicated to creating a safe environment for our target group and everyone who works at, with, for and on behalf of Nuffic. All employees have a duty to uphold the principles of this policy. They commit to safeguarding a work culture dedicated to creating that safe environment and preventing violence against our target group.

Nuffic considers 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 exact measures to be taken depend on the circumstances.

Financial misconduct

We strive to build relationships with suppliers, subsidy recipients, beneficiaries, governments, public officials, politicians and other stakeholders that are based on professionalism, trust and integrity.

We will never make illegal payments, perform or ask for illegal favours or take any other actions that could expose Nuffic to risks of financial loss, dependency, blackmail, extortion, legal sanctions or damage to our reputation. We have a zero-tolerance policy regarding all forms of fraud and corruption.

Abuses of power

Nuffic and its employees act in accordance with the following values to prevent abuses of power:

  • Objective
    In carrying out our activities, it is important that we maintain independent and objective relationships with individual parties in the field. Personal interests are avoided, and if personal interests are involved, these are kept strictly separate from business interests. All conflicts of interest or the appearance thereof are avoided. Nuffic is honest and transparent in this regard and can therefore always explain why specific decisions have been made.
  • Reliable
    Nuffic is a reliable partner, meaning that employees live up to expectations. 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. Rules, standards for things such as quality, and norms, social and otherwise, are adhered to, both in letter and spirit. Nuffic and its employees are held accountable for this and take responsibility accordingly.
  • Careful
    Decisions are made carefully, with thorough consideration of the various interests involved. Public funds and other resources are used 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 particularly to internet use and email. Personal and other data are handled confidentially.

3. Definitions

Violence against someone in our target group
All forms of violence, physical or mental abuse, abandonment or neglect, emotional and physical mistreatment, sexual abuse and exploitation, harassment and other forms of exploitation or violence in which a child, young person or student is the victim.

Such acts of violence can also occur online, including on websites, on social media or via mobile phones. These may entail deliberate acts involving the use of physical violence or abuses of power, as well as the failure to prevent violence against a child or young person.

Violence includes anything that people, groups, institutions or organisations intentionally or unintentionally do or fail to do that results in real or potential harm, or a high risk thereof, to the well-being, dignity, survival and/or development of a child or young person.

Harm
Any adverse effect on a person’s physical, psychological or emotional well-being or on their financial situation. Such harm can be the result of intentional or unintentional abuse or exploitation.

Fraud
Fraud is defined as any intentional act or negligence in which deception is used to obtain an advantage to which one is not entitled to and/or which affects the rights of others. Fraud is a broad concept and has many manifestations, such as deliberately providing false information or withholding information for (personal) (financial) gain or to disadvantage someone else.

Abuse of power, bribery and corruption
Misuse of authority for personal gain or attempting such misuse. This includes offering, promising, giving, accepting or requesting money, gifts or other private benefits in exchange for an illegal activity, abuse of power or other improper behaviour while carrying out the relevant activities.

Corruption can also entail nepotism or favouritism arising from a conflict of interest. Fraud and corruption are not necessarily aimed at the financial or material gain of one person. These practices may also involve intangible benefits such as status or information, and can benefit an individual as well as a group.

Protection of our target group
Our responsibilities and the preventive, reactive and referral measures that we take to protect our target group to prevent them from experiencing any form of injustice or disadvantage as a result of their involvement in activities that are carried out within the context of contractual obligations between Nuffic and subsidy recipients. With this in mind, care must be taken to ensure that such activities are carried out safely.

If someone raises concerns about the well-being of someone in our target group or if someone from our target group has fallen victim to violence, we will take appropriate and necessary measures to address the problem and the incidents will be analysed to enable continuous learning within the organisation.

Employees
People who receive a salary or compensation on a structural basis for their work at Nuffic, or people who receive remuneration from Nuffic or from an intermediary but are affiliated with another organisation. Interns, temporary workers and consultants also fall under this group. In addition, persons employed by Nuffic who are responsible for taking duties at Nuffic offices abroad also fall under this definition.

Manager
A Nuffic employee who is responsible for directly managing or supervising the work of other Nuffic employees.

People who work with or on behalf of Nuffic
People who, for example, visit our offices or projects and programmes in the Netherlands or abroad, and in that context may potentially come into contact with our target group via Nuffic. This can include journalists, media personnel, researchers and public figures.

The following categories of people also fall under this definition: members of the Board of Trustees and advisory councils, researchers, donors, consultants and contractors, employees and/or representatives of partner organisations (subsidy recipients and beneficiaries) and local government authorities (if acting under partnership agreements with Nuffic).

Partner organisations
Organisations that carry out activities together with us, on our behalf or with our funding (subsidy recipients and beneficiaries) as well as suppliers.

Target group
The ultimate beneficiaries of our activities. This includes but is not limited to children, young people, students, teachers and alumni. They participate in or use one or more projects, grants, training programmes, development projects, events for alumni or others or other Nuffic activities and are directly impacted by these activities. Nuffic or subsidy recipients and beneficiaries of Nuffic carry out these activities.

Our target group is located both in the Netherlands and abroad.

Child
In accordance with the United Nations Convention on the Rights of the Child and in the context of this policy, the word 'child' refers to any girl, boy, young woman, young man or child with a different gender identity who is under the age of 18 (Article 1 of the International Convention on the Rights of the Child). This target group is located mainly in the Netherlands.

Young person
Ain accordance with the definition of the United Nations, 'young person' refers to any young woman, young man or young person with a different gender identity who is between the ages of 15 and 24.

This group includes people in the categories of ‘children’, ‘adolescents’ and ‘adults’, but is used because of the assumption that young people have special needs in terms of protection and that special attention should therefore be paid to this group, taking into account the differences in comparison to younger children and older adults.

Student
Someone who is enrolled in a study programme at a secondary vocational or higher education institution in the Netherlands or abroad.

Teacher
Someone who teaches at an educational institution in the Netherlands or abroad and who purchases services from Nuffic. Teachers can also be alumni.

Alumni
People who have received grants from Nuffic in the past and who participate in Nuffic events in which they receive services from Nuffic and inform potential new direct beneficiaries of Nuffic about pursuing education in the Netherlands and possibilities to apply for Nuffic grants.

4. Roles and responsibilities

4.1 All Employees and People who work with or on behalf of Nuffic:

  • must commit and contribute to creating an environment in which our target group feels respected, supported, safe and protected;
  • may never commit acts that result in violence against anyone in our target group or that expose anyone in our target group to the risk of violence;
  • must be aware of and endorse the provisions of this policy;
  • must sign this Code of Conduct to indicate their compliance with the policy and the Code of Conduct;
  • must report concerns about the safety of our target group and any policy violations in accordance with the applicable procedures.

4.2 Managers must ensure that:

  • the people we work for (our target group) and the people we work with or have contact with are aware of the provisions of this policy, so that we can be confident that they feel – and also are – able to report all possible incidents to which members of our target group may fall victim;
  • employees are aware of the specific integrity-related responsibilities that apply to their position;
  • people who work with or on behalf of Nuffic are aware of the guidelines for implementation (see paragraph 7) that apply to their involvement in our activities;
  • they support and develop tools that ensure a safe environment for our target group and prevent violence against them;
  • the policy is fully integrated into their work processes and activities.

4.3 Managers who work outside the Netherlands must ensure that:

  • they follow the relevant local procedures that are consistent with this policy and the Code of Conduct. These local procedures must be updated regularly. The policy and the applicable procedures must be available in the local language or languages;
  • the guidelines for implementation (see paragraph 7) are applied in a way that is appropriate to (1) the specific context, (2) the people (employees and visitors) and the target group we work with, and (3) the processes, programmes, projects, events and activities that they carry out.

4.4 The organisations that work together with us on the implementation of our programmes, projects, processes, events and/or activities in which our target group is involved, must adhere to the guidelines in paragraph 7.

4.5 Employees of our partner organisations who work with, for or on behalf of Nuffic must:

  • sign this Code of Conduct to indicate their compliance with the policy and the Code of Conduct;
  • or comply with the Code of Conduct of the organisation they work for, provided that it is consistent and compatible with this policy.

4.6 All components of Nuffic strive for compliance with this policy by conducting checks and mandatory audits of the Code of Conduct.

5. Code of conduct

5.1 Interpersonal misconduct

Nuffic is committed to creating a safe environment for our target group. All staff have a duty to uphold the principles of this policy. They commit to safeguarding an environment focused on preventing violence against our target group.

Nuffic considers sexual exploitation and abuse by staff (including the people who work for, with or on behalf of Nuffic) as serious offences and therefore just cause for dismissal.

As an employee or person who works with, for or on behalf of Nuffic, I will therefore do the following:

I will comply with the policy and be open and honest with people in our target group who participate in our programmes, projects, processes, events and activities.

I will respect the rights, integrity and dignity of people in our target group and keep their interests in mind during my interactions with them, regardless of age, sex, gender, gender identity, sexual orientation, nationality, ethnic origin, colour, race, language, political or religious affiliation, marital status, disability, physical or mental health, family situation, socio-economic or cultural background, class or prior contact with the criminal justice system.

I will create and maintain an environment focused on preventing abuse and exploitation of our target group. In doing so, I am aware of the potential risks associated with my behaviour and my work. I take appropriate measures to minimise the risks to which our target group is exposed.

I will help to create an environment in which the people in the target group we work for:

  • are respected and have the opportunity to be involved in the decision-making process and the interventions related to their protection, taking into account their age, their maturity level and the development of their skills;
  • are well-informed about their rights in terms of safety and protection, and about what they should do if there is a problem.

I will demonstrate a high standard of professional conduct at all times, as a positive role model for our target group.

I will demonstrate understanding of the legal frameworks of our work and the associated procedures and apply these accordingly.

I will comply with all international standards and local laws regarding child labour and never hire children or young people under the age of 18 to perform domestic or other work. This is tantamount to exploitation and can have an adverse effect given their age and development, as it means they will have less time or no time at all for educational or recreational activities. For the child or young person in such a situation, there is also a considerable risk of injuries, exploitation and violence.

I will respect the privacy and personal lives of those in our target group. This means that I will never:

  • ask for personal data (including email addresses, phone numbers, contact details on social media, webcam or Skype addresses etc.) of people who are or have been involved in our activities, or invite them to share or accept personal data, or share my own personal data with these people, unless expressly permitted by Nuffic and/or for the purposes of Nuffic’s commercial considerations;
  • share information, help others to share information or support the sharing of information in any other way and via any means of communication if it concerns information that could be used to identify people in our target group or their family members, unless this is done in accordance with Nuffic’s media guidelines (managed by the Communication core activity’s Content team) and/or has been expressly permitted by Nuffic. Such means of communication include paper documents, photos and social media, among other things;
  • make contact with children from Nuffic’s target group if these children are not accompanied by another Nuffic employee or a supervisor from a subsidy recipient or beneficiary organisation. Such contact includes visits as well as all forms of communication via social media, email or letters.

If I go on an official visit for Nuffic abroad and would like to take photos or videos of people in our target group for personal use, I will always take care to:

  • consult the local Nuffic employee first to check whether it is acceptable to take photos in the local context, and whether or not the planned use of the photos or videos is consistent with Nuffic’s media guidelines (managed by the Communication core activity’s Content team);
  • request permission from the person (or in the case of young children, from their parent or guardian) and inform them of the exact purpose and planned use of the photos and videos (including where and how these will be used);
  • respect a possible negative reply and clearly indicate that refusing to give permission will have no negative consequences whatsoever;
  • ensure that the images taken are respectful and do not infringe on the dignity or privacy of the person depicted;
  • ensure that the use of the images does not expose the person to the risk of being identified or located, if this could compromise the person’s safety;
  • never upload images of people from our target group to any social media websites other than corporate Nuffic media sites and social media accounts without Nuffic’s full and express consent.

I will report concerns, suspicions, incidents and accusations involving actual or potential violence against someone in our target group and act in accordance with the applicable procedures at the office where I work.

I will give my full and confidential cooperation to any Nuffic investigation into suspicions or allegations of violence against people in our target group.

I will immediately report all allegations, convictions and other consequences of a criminal offence that have occurred before or during contact between me and people from our target group, and that are related to the exploitation or abuse of someone from our target group.

I will not:

  • abuse or exploit anyone in the target group or behave in a way that could cause someone in the target group to be exposed to risks;
  • engage in any type of sexual activity or have physical/sexual relations with a person under the age of 18, regardless of the locally applicable age of sexual consent. Being unaware of a child’s actual age cannot be used as a defence (ST/SGB/2003/13 of the United Nations: Secretary-General’s Bulletin on Special measures for protection from sexual exploitation and sexual abuse, 2003);
  • have sexual relations with people between the ages of 18 and 24 who are part of Nuffic’s target group, which would jeopardise the credibility and integrity of Nuffic’s work and would be based on an imbalance of power;
  • use corporal punishment or physical force to punish people from our target group;
  • involve people from our target group in any form of sexual activity involving the exchange of money, labour, goods or services, including sexual favours or any other form of humiliating, degrading or exploitative behaviour. This also includes the exchange of conditional aid to beneficiaries (ST/SGB/2003/13 of the United Nations: Secretary-General’s Bulletin on Special measures for protection from sexual exploitation and sexual abuse, 2003);
  • express myself or behave towards people in our target group in a way that is inappropriate, offensive, abusive, sexually provocative, demeaning or culturally inappropriate;
  • caress, hold, kiss, embrace or touch people from our target group inappropriately or without regard for their cultural traditions;
  • allow anyone from our target group with whom I have professional contact to spend the night with me in any type of private residence or accommodation;
  • sleep in the same bed or room as someone from our target group with whom I have professional contact. If it is necessary to sleep near unaccompanied people from our target group, I will make sure that another adult is present and that all established procedures are followed;
  • perform acts of an intimate nature for people from our target group with whom I have professional contact, which they can also do themselves (e.g. accompanying someone to the toilet/bathroom, helping him or her to get dressed or undressed, etc.);
  • spend time alone – and away from others – with children from our target group with whom I have professional contact. I will always make sure that another adult is present and/or that I spend time with children from our target group in a public place where other people can see us and know we are there;
  • hit people in our target group or subject them to any form of physical abuse or mistreatment;
  • deliberately act in a way that is humiliating, degrading or offensive towards people in our target group or commit any other act that is tantamount to emotional abuse;
  • treat certain people in our target group differently, discriminate against them or favour them over others;
  • start a relationship with people from our target group or engage in practices or adopt behaviour that can be considered or interpreted as offensive or abusive in any way;
  • tolerate illegal, dangerous or abusive behaviour from people in our target group, and/or participate in such behaviour myself;
  • use computers, mobile phones, digital cameras, camcorders or similar media devices to exploit, harass or intimidate people in our target group.

5.2 Financial misconduct

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, perform or ask for illegal favours or take any other actions that could expose Nuffic to risks of financial loss, dependency, blackmail, extortion, legal sanctions or damage to our reputation. We have a zero-tolerance policy regarding all forms of fraud and corruption.

As an employee or person who works with, for or on behalf of Nuffic, I will therefore:

  • handle Nuffic assets and resources appropriately;
  • ignore or reject all allusions to engaging in fraud or corruption;
  • bring someone along as a witness to assist me in critical situations;
  • refuse to agree to anything that is wrong;
  • record the details of the situation as soon as possible in the event of a request to commit fraud or corruption, an attempt to commit fraud or corruption, or a case of actual fraud or corruption;
  • immediately report all such requests, attempts and cases of actual fraud or corruption to my manager or to an internal or external confidential advisor;
  • inform my manager or an internal or external confidential advisor as soon as possible and share relevant details with this person, in the event of suspected fraud or corruption or of suspicious actions and situations (see examples under ‘Red flags’);
  • report imminent or potential conflicts of interest to my manager at the earliest possible stage;
  • cooperate fully during investigations by sharing all relevant information with the appropriate people and agencies and by participating in interviews.

I will not:

  • accept payments, gifts or other favours from public officials, politicians, government agencies, other regulatory or policy-making agencies, suppliers, partner organisations or other parties, with the aim of influencing or rewarding a decision relating to that party or gaining any other illegal or unfair advantage. Exceptions include gifts valued at no more than €50 given in the context of the partnership and clearly not intended to influence decisions;
  • make payments to, give gifts to or do favours for public officials, politicians, government agencies, other regulatory or policy-making agencies, suppliers, partner organisations or other parties, with the aim of influencing or rewarding a decision by that party or gaining any other illegal or unfair advantage. Exceptions include gifts valued at no more than €50 that Nuffic gives to the party concerned in the context of the partnership and are clearly not intended to influence decisions.

Red flags

The following examples of red flags (note: this list is not exhaustive) may be cause for suspicion and can be helpful in identifying fraud and corruption:

  • Irregularities in financial records, such as:
    Descriptions of transactions that are vague, inconsistent, incomplete or incorrect;
    Incorrect, incomplete or unusual details about the identity of the other party in a transaction;
    Abnormally large payments without an explanatory note;
    Unusual payment patterns or structures;
    The use of different accounts, which can allow incorrect payments to be concealed;
    Erroneous, unusually large or an unusually high number of invoices and expense claims.
  • A party that you hire does not seem to have the qualities needed to perform the work for which it has been contracted.
  • A party that you hire refuses to provide information demonstrating its compliance with anti-fraud laws and regulations.
  • Requests to make payments to a party that you have not contracted, in a country where you are not carrying out activities, in cash or in a non-traceable currency (i.e. untraceable funds).
  • A party that disproportionately depends on contacts with politicians or government officials to promote our interests, instead of on employees with their own knowledge and expertise.
  • A representative who approaches you on behalf of a third party but wishes to keep the identity of this third party a secret.
  • A party that you contract does not have an anti-fraud or corruption policy, a code of conduct or related training for employees.
  • In case of an audit: misrepresentation or refusal to cooperate.

Special situations

Gifts:
It is against policy to make payments for gifts, trips, entertainment or other forms of donations to external parties, with the exception of minimal hospitality costs if this external guest is attending an official event, and only if the payment of these costs does not create a potential conflict of interest. This does not include the payment of costs for an external party that has been contracted to promote our work.

Government officials:
We maintain good and honest working relationships with many different government agencies in various countries in order to open offices, hire local staff, raise funds and carry out programme activities. We will therefore neither encourage nor reward inappropriate public administration. Inappropriate public administration includes the following in particular:

  • Facilitating payments:
    Payments to government officials in exchange for services that should actually be provided even without such payment. Facilitating payments are prohibited under Dutch law. As a result, we have a zero-tolerance policy. Employees must be aware that some facilitating payments are hidden in the price of the services.
  • Programme activities:
    Particularly when government agencies or officials are involved in the planning and execution of programme activities and in the selection and payment of suppliers. We make decisions on these matters objectively and are not swayed by attempts to influence our judgement.

Coercion:
In some situations, payments must be made under coercion if the life, health, safety or freedom of employees or people in their immediate vicinity is at stake. Employees who are confronted with this must report it to their supervisor immediately, and they will not be punished.

5.3 Abuses of power and conflicts of interest

Nuffic and its employees act in accordance with the following values:

Objective:
In carrying out our activities, it is important that we maintain independent and objective relationships with individual parties in the field. Personal interests are avoided, and if personal interests are involved, these are kept strictly separate from business interests. All conflicts of interest or the appearance thereof are avoided. Nuffic is honest and transparent in this regard and can therefore always explain why specific decisions have been made.

Reliable:
Nuffic is a reliable partner, meaning that employees live up to expectations. 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. Rules, standards for things such as quality, and norms, social and otherwise, are adhered to, both in letter and spirit. Nuffic and its employees are held accountable for this and take responsibility accordingly.

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 particularly to internet use and email. We handle personal and other data confidentially.

As an employee or person who works with, for or on behalf of Nuffic, I will therefore:

  • formulate agreements with clients, contractors, subsidy recipients, beneficiaries and suppliers as clearly as possible, so that no misunderstandings or false expectations can arise;
  • make exceptions to rules and procedures in a consistent manner only, so that one institution, scholarship recipient or language assistant will not be ‘better off’ than another, for example. Consult with my manager before making an exception to a rule or procedure;
  • prevent conflicts of interest when using consultants and selecting new employees. This means that, if people I know well in my private life are under consideration in the selection process to carry out work that I am personally in charge of or responsible for, I will take extra care to ensure that the selection is made based on objective criteria. When in doubt about a potential conflict of interest, I will ask others to make the selection and I will not be involved in the selection process myself;
  • only use personal data (such as information about alumni or credential evaluation applicants) for the purpose for which it has been provided and ensure that it is not retained for longer than necessary;
  • only make posts on social media if these are in line with Nuffic’s role and policy. When in doubt, I will discuss this with my manager;
  • report ancillary activities to my manager. My manager and I will jointly assess whether there is a conflict of interest or the appearance thereof and record agreements in my employee file. In the event of a conflict of interest or the appearance thereof, I will stop the ancillary activity or my work for Nuffic;
  • report to my manager as soon as possible if I start a relationship with a direct colleague, my manager or (in case of managers) an employee whom I manage, in order to determine what I can do to prevent a conflict of interest or the appearance thereof from arising. If there is indeed a conflict of interest or the appearance thereof, one of the two people in the relationship will carry out work within another team where there will no longer be a conflict of interest or the appearance thereof;
  • report to my manager as soon as possible if I have to carry out different types of work that could involve a conflict of interest or the appearance thereof, such as combining activities within Nuffic’s statutory tasks and activities that fall outside of Nuffic’s statutory tasks. If my manager indeed determines that there is a conflict of interest or the appearance thereof, I may need to transfer some of the tasks to a colleague.

I will not:

  • give preferential treatment to close contacts in my network by, for example, giving a more detailed answer to a question, delivering a faster credential evaluation or providing more intensive service through aninternational Nuffic office;
  • review requests for subsidies, credential evaluations or other services from people I know; in these situations, I will consult with my manager to determine which colleague can take over the request;
  • extend a business trip by more than 72 hours (including the total time before and after the business trip). I will pay for the additional costs of this extra time myself; any savings will be credited to Nuffic. No partners, friends or children are allowed on business trips, even if they cover the costs themselves;
  • disseminate information within or outside of Nuffic that clearly is or could be confidential in nature, without the express consent of the sender. Exceptions include violations of this Code of Conduct and violations of Dutch law;
  • use my Nuffic email account for private purposes or for ancillary activities, such as to promote my own ancillary activities or those of others;
  • use Nuffic’s email address list or details of colleagues, customers, suppliers, partner organisations or others in Nuffic’s network for private purposes or ancillary activities.

6. Compliance with policy and sanctions

In the event of a violation of this policy and the accompanying Code of Conduct, an investigation will be launched based on the relevant disciplinary procedures and contractual agreements, or the file will be handed over to the official authorities for the purpose of launching a legal investigation under the laws of the country where the individuals concerned work.

Violations may be punished with sanctions, including disciplinary actions that can result in dismissal, the severance of all ties including contractual agreements and, if necessary, legal proceedings or other appropriate measures.

If a legitimate suspicion is expressed regarding an alleged case of violence against a child or young person, but upon investigation this suspicion turns out to be unfounded, no measures will be taken against the person who reported the suspicion. However, appropriate sanctions will be imposed in the event of false or malicious accusations.

If an employee identifies circumstances (either in the organisation or via suppliers or other external stakeholders) that violate the policy or the Code of Conduct, then in addition to reporting this to his or her manager, the employee may also consult the internal or external confidential advisor. The reporting procedure and information about the confidential advisors can be found on Next and in the employee manual.

Allegations and suspicions that have been reported in good faith will never have negative consequences for the whistle-blower, regardless of the final outcome of the investigation and even if the report turns out to be unfounded. If it becomes clear that the report was intentionally made to tarnish the image of innocent parties, this will be considered a serious offence for which sanctions may be imposed.

Individual behaviour outside the workplace and involvement with our organisation

We do not impose a system of beliefs and values that Employees and People who work with or on behalf of Nuffic must adhere to in their private lives.

Nevertheless, things that they do outside of working hours that are deemed inconsistent with this policy will be considered a policy violation. All Employees and People who work with or on behalf of Nuffic must therefore adhere to the principles of the policy in the workplace and elsewhere.

7. Guidelines for implementation at partner organisations

It is important that our partner organisations create an environment in which they (1) combat deliberate unacceptable behaviour, but also (2) become more aware of unwitting, well-intentioned behaviour that can have negative consequences.

To ensure both these aims, we expect our partner organisations to have a framework that consists of the following components:

  • Prevention:
    Prevention starts with drafting and adopting a policy and a code of conduct. These serve as guidelines for everyone who works at, for or with the partner organisation.
  • Awareness and identification:
    The policy and code of conduct must then be put into practice and embedded in the activities and work processes of the partner organisation and the manner in which these things are conducted (i.e. the behaviour).
  • Reporting and follow-up measures:
    There must be a procedure for reporting signs of policy and code of conduct violations, both internal and external.
  • Accountability:
    Reports and their handling must be documented and reported. The subject of integrity must also be included as a policy topic in the annual report and discussed in the regular policy meetings with Nuffic as the client.

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