medico international

Corruption Prevention

Guidelines for the work of medico international


Through its work, medico international fights for the human right to the best possible access to health. The working principles of mi include a partner-oriented approach, reliability, cause-driven work, a development orientation and the pursuit of maximum transparency.
Accountability and transparency are the key prerequisites for the prevention of corruption. Since 1992 the German Central Institute for Social Issues (Deutsches Zentralinstitut für soziale Fragen or DZI) has acknowledged mi's compliance with applicable standards of accountability and transparency and its purposeful and effective use of resources.

These guidelines should serve a preventive function and identify risks in equal measure, while providing a course of action through clear instructions. Our credibility among partners, the target group and donors will thus be further strengthened.

1. Scope

The provisions of these guidelines apply, where not otherwise agreed individually, to:

  • staff in Germany, at overseas facilities and on overseas projects;
  • German staff on partner projects as part of cooperation efforts with mi;
  • members of the board;
  • consultants and other professional persons who work for mi on a contractual or freelance basis.

Like the Code of Conduct, these guidelines are an integral part of full-time, contractual and freelance work agreements as well as partnership agreements and thus serve as a reference for corruption prevention. Violation of the guidelines can lead to immediate termination of contracts and cessation of cooperation.

2. Definition of corruption

For the purposes of these guidelines corruption is defined as the misuse of entrusted power for private gain. This includes the offering, giving, requesting or accepting of gifts, loans, rewards, commissions or any other benefit to or from a third party as an incentive to do something within the scope of normal working relations that is dishonest, illegal or a breach of trust.
Furthermore the misappropriation of project funds for purposes not agreed, nepotism (cronyism), patronage, the falsification of documents and so-called facilitation payments count as corruption according to the guidelines.
The following crimes are, among others, instances of corruption: bribery, granting and accepting undue advantage, fraud and embezzlement, competition-restrictive agreements and money laundering.

3. Rules of conduct

The groups named in section one pledge to uphold the following rules:

  • Corruption in any form, whether direct or indirect, is prohibited. This includes the return of parts of a contractual payment (kickback), the use of other means or channels for illegal payments to contractors, suppliers, partners, their employees or public officials and the acceptance of bribes or kickbacks by or for the benefit of relatives.
  • The payment of bribes or other incentives with the objective of ensuring or accelerating a regulatory process, for which a claim is pending, is not allowed.
  • The offering or accepting of gifts, entertainment or reimbursement of expenses is prohibited insofar as they adversely affect competition and exceed the framework of sensible and reasonable expenses. The same applies to influencing decisions on project cooperation.

4 Requirements of mi

MI is committed to using the guidelines to combat corruption and is committed to avoiding perceivable conflicts of interest:

  • The Board makes the guidelines a matter of its policies, provides the necessary resources and actively supports management in the guidelines' implementation.
  • Management ensures that staff in Germany, at overseas facilities and on overseas projects are familiar with and observe the business principles. Awareness of problems must be actively promoted.
  • It should be clear that no employee will suffer a disadvantage from refusing to pay bribes or render bribery services.
  • Staff are encouraged to report offences and concerns as early as possible. To this end, secure, accessible and confidential information channels are being put in place. The first stop for external incidents is the executive director and for internal incidents the chairperson of the board or his/her deputy (whistle-blowing).
  • Particularly at the beginning of the first joint project, partner organisations are to be adequately informed concerning compliance with the principles. Medico reserves the right to repayment. Attention shall be paid to control structures at partner organizations. Solutions for foreseeable project financing gaps at partner organizations must be discussed before the start of projects. In the event of unforeseen financial shortfalls, it should be conveyed to partners that dialogue should be sought to search for appropriate solutions together.
  • Violations of the rules by mi employees or partner organisations will be dealt with through disciplinary or contractual sanctions (warning, termination, cessation of cooperation, etc.).
  • MI organizes its procurement practices fairly and transparently and complies with the guidelines when using public funds.
  • Any indication of corruption will be investigated. Following an assessment of the validity of the allegation further investigatory procedures will be established. The decision-making will lie with an authority outside the investigation process which, when the office itself is affected, is to be selected by the board chairperson. The Board shall be promptly and fully informed in every case.

5. Queries

Queries can be directed to the executive director.

Frankfurt, 29 July 2008

Thomas Gebauer
Executive Director

medico international