Table of Contents

1. About GOHA

 1.1 Our Vision

 1.2 Our Mission

2. Scope and Application

 2.1 Policy Applicability

 2.2 Organizational Coverage

 2.3 Individual Responsibilities

 2.4 Commitment to Prevention and Response

3. Definition of Fraud

 3.1 Examples of Fraudulent Acts

4. Fraud Risk Reduction

 4.1 Fraud Awareness

 4.2 Programme & Project Design

 4.3 Fraud Risk Assessment

 4.4 Internal Controls

 4.5 Integrity & Best Practices

 4.6 Standards & Codes of Conduct

5. Reporting Fraud

 5.1 Key Info Required

 5.2 Supporting Documents

6. Confidentiality

7. Whistleblower Protection

8. Handling & Review of Allegations

9. Actions Following Investigation

10. Remediation & Lessons Learned

Executive Summary

1. About GOHA

Gate of Hope is an independent, philanthropic organization providing social services across Afghanistan and Asia, focusing on Health, Women's Empowerment, Children Protection, and Education. Since 2021, GOHA has maintained excellence through research, capacity building, and training initiatives.

Our team of professionals ensures high-quality service delivery and partnership, addressing both immediate needs and long-term development.

1.1 Our Vision

To realize projects successfully even in challenging conditions, serving clients across governmental, non-governmental, and private sectors nationwide and internationally.

1.2 Our Mission

Empower Afghan women and youth, support children affected by conflict, and promote education, well-being, and resilience. Integrity, transparency, and accountability guide all our work.

2. Scope and Application

This policy applies to all GOHA personnel and partners across all operations and programs. Individuals must uphold integrity, report suspected fraud, and comply with GOHA procedures. Reports made in good faith are protected; false or malicious reports may face disciplinary action.

3. Definition of Fraud

Fraud is any act or omission to mislead or hide information for personal gain or to cause harm. Examples include forgery, false claims, procurement manipulation, misuse of IT accounts, undisclosed conflicts of interest, and falsifying records.

Fraud is categorized as:

• Category 1 – Serious and complex fraud (large-scale embezzlement, senior management involvement)
• Category 2 – Simple entitlement fraud (minor misrepresentations for personal benefit)

4. Fraud Risk Reduction

GOHA promotes awareness, integrates fraud prevention in project design, conducts risk assessments, and applies robust internal controls. Integrity and best practices are emphasized in recruitment, contracting, and adherence to ethical standards.

5. Reporting Fraud

Fraud should be reported confidentially via email (fraud@goha-afg.org), in person, or in writing. Reports must include details of the incident, persons involved, evidence, financial impact, actions taken, and recommendations. Good-faith reports are protected.

6. Confidentiality

Fraud reports and investigations are confidential. Access is limited to necessary personnel, and unauthorized disclosure is prohibited.

7. Protection for Whistleblowers

Personnel reporting in good faith are protected from retaliation. GOHA may provide alternative arrangements, reassignment, and enhanced confidentiality. False reports are not protected.

8. Handling & Review of Allegations

Investigations are impartial, confidential, timely, and professional. The team reports directly to the Board and may coordinate with external authorities if needed.

9. Actions Following Investigation

Substantiated fraud leads to appropriate disciplinary, administrative, contractual, or legal actions based on severity. Category 1 fraud may be referred to national authorities. Recovery of losses and process improvements are prioritized.

10. Remediation & Lessons Learned

Insights from investigations are used to address systemic weaknesses, improve processes, and prevent recurrence. Periodic reviews ensure effective mitigation and enhancements.

Executive Summary

GOHA is committed to integrity, transparency, and accountability. This Anti-Fraud Policy guides the prevention, detection, and reporting of fraud. All personnel must adhere to the policy and report misconduct promptly. GOHA maintains zero tolerance for fraud and protects whistleblowers from retaliation.