Integrity Policy
Registered in the Netherlands | Effective: March 4th, 2026
1. Purpose
This Integrity Policy sets out the standards and procedures by which Ackee Seed Foundation ensures ethical conduct, financial accountability, and responsible governance across all its activities. It applies alongside the Code of Conduct and the Child Safeguarding Policy, which address interpersonal conduct and the protection of children and vulnerable persons respectively.
This policy is binding on all members of the Management Board, the Supervisory Board, staff, consultants, volunteers, and any person acting on behalf of the Foundation.
2. Governance and Accountability
The Foundation operates under a two-tier governance structure:
Management Board: responsible for the day-to-day management and direction of the Foundation, consisting of the Executive Director (Chair), Secretary, and Treasurer.
Supervisory Board: responsible for overseeing the policy and conduct of the Management Board and providing independent accountability.
Decision-making safeguards:
Major decisions require the joint sign-off of at least two Management Board members.
The following decisions require prior written approval from the Supervisory Board: adoption of budgets and policy plans; long-term partnerships; taking on financial loans; any agreement of far-reaching significance.
If the Management Board is deadlocked on a decision, the matter is referred to the Supervisory Board for resolution.
Annual accounts must be signed by all Management Board members and subsequently adopted by the Supervisory Board.
3. Financial Integrity
The Foundation is committed to the responsible, transparent, and accountable management of all funds and resources.
Principles:
All funds raised for a specific purpose will be directed exclusively to that purpose.
No funds will be used for personal gain by any board member, staff member, or volunteer.
Supervisory Board members receive no remuneration. Reasonable expenses may be reimbursed upon presentation of documentary evidence.
A dedicated Foundation account is used solely for the Foundation's transactions.
Administrative costs drawn from Foundation funds will be documented, approved by the Board, and disclosed in financial reporting.
Financial records are retained for a minimum of seven years in accordance with Dutch law.
Annual accounts are prepared and presented to the Supervisory Board within six months of the close of each financial year.
Authorisation:
Expenditures and disbursements above agreed thresholds require joint authorisation by at least two Management Board members.
No funds will be disbursed to any external organisation or partner without prior due diligence and a confirmed, signed agreement.
4. Conflicts of Interest
A conflict of interest arises when a board member, staff member, or volunteer has a personal, financial, or professional interest that could compromise, or appear to compromise, their objectivity or loyalty to the Foundation.
Procedure:
Any actual or potential conflict of interest must be declared immediately to the other board members or to a direct supervisor.
The person with the conflict must not participate in any discussion or decision related to that matter.
The declaration and outcome will be recorded in the meeting minutes.
Where a conflict prevents a Management Board resolution from being adopted, the matter is referred to the Supervisory Board.
5. Anti-Fraud and Anti-Corruption
The Foundation has a zero-tolerance policy toward fraud, bribery, corruption, and the misuse of resources in any form.
This includes but is not limited to:
Misappropriation or misuse of Foundation funds or assets
Falsification of records, reports, or documentation
Offering or accepting bribes, gifts, or favours that could influence decisions
Misrepresentation of the Foundation's activities or impact
Any suspected fraud or financial misconduct must be reported immediately in accordance with Section 6 of this policy. The Foundation reserves the right to refer matters to the appropriate legal authorities.
6. Reporting Concerns
Any person bound by this policy who becomes aware of a potential breach, whether financial, ethical, or governance-related, is expected to raise it without delay.
Concerns may be raised with:
A direct supervisor or manager
Any member of the Management Board
The Supervisory Board, if the concern involves the Management Board
Reports will be handled confidentially and without retaliation against the person raising the concern. Anonymous reports will be accepted and taken seriously.
This reporting obligation is referenced in the Code of Conduct. The same channel applies to concerns arising under the Child Safeguarding Policy.
7. Compliance
The Foundation operates in compliance with:
Dutch civil law governing foundations (Boek 2 Burgerlijk Wetboek)
The Foundation's Articles of Association (Statuten), signed March 4th, 2026
Applicable data protection legislation (AVG / GDPR)
The laws and regulations of any country in which the Foundation operates or delivers programmes
Partners and collaborators are expected to uphold the same standards of legal and ethical compliance in their own operations.
8. Breaches and Sanctions
Breaches of this policy will be taken seriously and handled in proportion to their nature and severity. Depending on the circumstances, this may result in:
A formal warning
Suspension of responsibilities
Termination of involvement with the Foundation
Referral to relevant legal or regulatory authorities
The Management Board, with oversight from the Supervisory Board, is responsible for determining the appropriate response to any breach.
9. Review
This policy will be reviewed annually by the Management Board and Supervisory Board, or following any significant change in the Foundation's operations, structure, or legal obligations.
Next review: March 2027
This policy should be read alongside the Code of Conduct and the Child Safeguarding Policy. Stichting Ackee Seed - Utrecht, Netherlands Registration: KvK 99987740