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, the government, educational institutions and of course our own employees (both in the Netherlands and abroad): 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.

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

• Nuffic operates in an environment where unequal power dynamics between teachers and students/pupils can occur.
• Nuffic’s activities indirectly serve children, young people and students, who are particularly vulnerable to abuse of any kind.
• Some of Nuffic's activities involve financing projects in developing countries, creating a power imbalance between Nuffic and the organisations receiving funding (the grant provider and the beneficiary/recipient). The same applies to the relationship between Nuffic's partner in the Netherlands receiving funding and the local partner executing the project together with the partner in the Netherlands. This is especially relevant in countries with a different culture, political situation or power structure.
• Nuffic provides services ultimately used by students and pupils who, by making use of these services, can find themselves outside their own familiar environment. This includes both foreign students and pupils in the Netherlands and Dutch students and pupils 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.

The policy, which applies to both our head office in The Hague and our international offices abroad, will 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 in developing countries, 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 recipient, between ‘the West’ and developing countries, between a teacher and a student, but also at our head 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.

An effective integrity policy starts therefore with raising awareness of this power imbalance and relationship of dependence, and the safety risks they involve for everyone who works at, with, for and on behalf of Nuffic. This allows us to work together in a more equal way.

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 and preventing violence. 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 precise nature of these measures depends on the circumstances.

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

This concerns jeopardising the confidentiality, integrity and availability of information within Nuffic or its chain partners, either intentionally or through negligence. All employees are obliged to adhere to the principles and policy frameworks in the domain of information security & privacy and to follow instructions in this regard. The policy on information security is included as an internal annex.

Abuse of power and conflicts of interest

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 in the field are independent and objective. Personal interests are avoided, and where personal interests exist they are 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. 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

1. Prevention

Prevention starts with a clear code of conduct, which serves as a guide for everyone who works at, for or with Nuffic anywhere in the world. 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 is available online. Integrity is also safeguarded in our recruitment and selection policy. The changes to the recruitment and selection policy are included as an internal appendix.

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 (both in the Netherlands and abroad):
  • Employees explicitly sign the Nuffic Code of Conduct and the regulations on responsible use of email, the internet and ICT resources.
  • 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 the topic of awareness.
• Subsidy recipients and beneficiaries : Our integrity policy and code of conduct are integrated into contracts and process descriptions.
• 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. Reporting and follow-up

There are a number of ways to report suspected misconduct and to conduct an investigation into possible infringements of the policy and code of conduct, both internally and externally.

Internal and external: reporting suspected misconduct

A report form for reporting suspected misconduct is made available online. This form can be used internally and externally:

• Internally by employees, interns, consultants and other individuals who carry out work for Nuffic
• Externally by suppliers, customers and clients, beneficiaries and subsidy recipients. This form is posted on the website and can be sent to Nuffic by email.

After a report is made to the management team member or integrity focal point, the decision can be made to launch an internal investigation.

Internal: confidential advisers and whistle-blower policy

In addition to the above-mentioned reporting procedure, there are designated confidential advisers and a separate whistle-blower policy. This policy can be found in section 8.5 of the staff handbook. The whistle-blower policy provides additional protection for the person making a report. The internal whistle-blower policy can be used by employees, interns, consultants and other individuals who carry out work for Nuffic to make an internal report of suspected misconduct.

Reporting suspected misconduct to the Ministry of Foreign Affairs and the Ministry of Education, Culture and Science

The Ministry of Foreign Affairs has made agreements on the reporting of possible integrity violations by contractors (such as Nuffic). Violations must be reported in the following cases:

• Violations of the contractor’s own code of conduct, and/or
• Legal violations, and/or
• If the incident involves management

Reports are made to the normal action line, using the online report form (page in Dutch).

For any programmes that fall under the Ministry of Education, Culture and Science, misconduct should be reported using the Education Inspectorate contact form.

External complaints procedure

There is already a complaints procedure for external parties, as set out in the General Administrative Law Act. This policy also includes an investigation procedure. The complaints procedure and associated investigation procedure continue to exist and are separate from the previously described procedure for reporting misconduct.

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. The HRM team under the Operations pillar 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.