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Anti-corruption and Whistleblowing Policy

Skandinaviska Barnmissionen (SBM) / Children’s Mission Sweden (CM)

"Corruption is to use one’s position to obtain unfair advantage

for one’s own account or for others. "

- Transparency International

“Corruption: Abuse of position of trust for personal gain, such as bribery, who is the donor's crime, and corruption, the receiver offense.”

-      National Encyclopedia

1.  Introduction

Children’s Mission is committed to maintaining the highest standards of integrity and transparency in all our operations and within our organization. Standing up for human rights and fighting corruption are important parts of reaching Children’s Mission’s vision of a world where everyone can live a dignified life. As an organization dedicated to providing humanitarian aid and fostering development, we are fully committed to ensuring that our work is free from any form of corruption.

We have a zero-tolerance towards corruption and will take all necessary steps to prevent, detect, and respond to corruption within our organization and its operations.

2.  Scope

This policy applies to all employees, including staff, volunteers, interns, contractors, consultants, partners and anyone who contributes to the work of Children’s Mission or our partner organizations, as well as stakeholders affected by our activities. References to “CM” in this Policy refers to Children’s Mission, all members and the Regional Office.

3.  Definition and examples of corruption

Corruption is generally defined as the abuse of entrusted power or authority for personal gain. It involves acts that are unethical, illegal, or involve the violation of laws, rules, or norms in order to benefit an individual or group at the expense of fairness, transparency, and public trust.

Corruption can take many forms, including but not limited to: bribery, fraud, favoritism, nepotism embezzlement, extortion and other unethical behaviors. Children’s Mission are aware that the risk of corruption exists in all contexts. However, there are specific risks associated with development and disaster response, of which the following should be emphasized:

3.1  Examples of external risks:

• During and immediately after a natural disaster or a conflict situation in which the work is conducted in a chaotic environment that is very difficult to Goods and services are to be procured and delivered in a short period of time.
• A high level of corruption in society in general risks affecting organizations and individuals involved in development cooperation: a corrupt attitude becomes normative at all levels.
• Weakly developed democracies and lack of
• Low and uneven economic
• Weakly developed civil societies and the lack of media
• When development aid contains a lot of money compared to the local
• For the procurement of goods or
• Scarcity of goods or services, and high inflation hampers the assessment of reasonable

3.2  Examples of internal risks:

• Extensive cash management of an organization or
• Weak management of the organization or project, which may lead to a lack of internal
• Weaknesses in administrative systems; financial procedures, internal control, procurement procedures, etc.
• Close friendships between colleagues and / or representatives of the contractual
• Excessive confidence in employees can pose a risk of regulatory, and documentation is not

3.3. Warning Signs

Corruption is often difficult to detect but there are some signals that may indicate irregularities that may require follow-up. Below are some examples.

• Lack of transparency in the organization or
• Unclear or inadequate structures for the allocation of responsibilities and accountability within the organization or project.
• All power is concentrated in one or a few people in the
• Staff have expensive habits / high standard of living relative to their
• The organization does not produce consolidated financial
• Project budgets are unclear and difficult to relate to planned
• Difficulty in seeing consistency between project activities and costs is incurred, in other words: high costs under financial report in relation to what has been implemented according to the written report.
• Reports are coming in late and are
• The Financial Manager has insufficient
• Questions will be answered
• Time pressure when needs are said to have to be met

4.  CM’s anti-corruption approach

Children’s Mission is committed to conducting its operations with dignity, participation, sustainability and transparency. CM are committed to creating a learning environment where concerns regarding corruption or unethical conduct can be raised and addressed without fear of retaliation. CM’s approach to prevent and detect corruption is based on:

• Transparency - Corruption thrives in closed systems, therefore CM seeks to be a role model in terms of openness / transparency at every stage.
• Participation - CM strives to involve partners in all aspects of a project. Those who feel involved are probably less inclined to abuse the project's funds.
• Ethics and morality - Based on Christian core values concerning the ethical and moral approach in development cooperation, CM has high demands on the partners. The meaning of ethics is regulations, principles, values, policies and Morality is the application of ethics: to comply with the ethical principles.
• Ethical Conduct- We expect all staff and associated persons to uphold the highest standards of ethical conduct, ensuring their actions are transparent, legal, and aligned with the organization’s values. CMs Code of Conduct shall be signed by all CM representatives.
• Dialog - CM have a close dialogue with the aim of creating a relationship of trust with There is a lot of value in reading between the lines and capturing the values and behaviors that are not apparent in written correspondence.
• Audit - A requirement for cooperation with CM is that the partner conducts annual certified audit reviews and submits an annual report.
• Control / accountability - for all partners there are elaborate systems that regulate the distribution of responsibilities. CM does random checks in the accounting records and has a discussion around cost items.
• Contract / Agreement - When starting up in new countries and / or with new partners, the partnership is regulated in the contract / agreement. This policy is mandatory for all new partners to sign and follow.
• Compliance with Laws and Regulations- Children’s Mission adheres to all applicable anti-corruption laws and regulations, including international and local laws. Employees and associated persons must act in accordance with these legal requirements.
• Learning - CM is actively working to develop and strengthen local organizations' capacity for planning, implementation, monitoring and evaluation. Accounting, financial reporting and monitoring is a priority.
• Bribery and Corruption- Bribery, whether direct or indirect, is prohibited. Employees and associates must not offer, promise, give, solicit, or accept any form of bribe or kickback in connection with any activity involving the organization.
• Independent / disqualification - CM advocates that family relations within the partner organization are avoided.
• Whistle blowing- a system and channel for whistleblowing is essential for an effective anti-corruption policy. It provides a safe and confidential channel for someone within or outside the organization to report misconduct, unethical behavior, fraudulent activities, or violations of the organization’s values.
• Gifts - CM representatives may occasionally be offered While small, symbolic items (e.g., pens, notebooks, or calendars) can be accepted, gifts of higher value (e.g., gift cards, event tickets, travel, or personal benefits) should always be politely declined. Gifts must never create a conflict of interest or appear to influence professional judgment. Items such as candy, chocolate, or fruit should be shared with the team. If there is any uncertainty, CM representatives should consult the administrative manager or General Secretary

5.  Children’s Mission Whistleblowing Policy

5.1 Purpose of Whistleblowing:

Whistleblowing refers to the act of reporting any suspected wrongdoing, unethical behavior, violations of laws, regulations, or organizational policies that could harm the organization, its staff, beneficiaries, or the public. Whistleblowing can be done by anyone within or outside the organization who raises the alarm about an occurrence, potential occurrence, or past occurrence of serious misconduct within the organization or in partner organizations. If a whistleblower report is made, the individual is entitled to protection under the Whistleblower Act (Law 2021:890), given certain conditions.

5.2  What can be reported?

• Actions that violate applicable legislation, such as fraud or other financial
• Misuse of the organization's
• Failure to comply with any of Children’s Missions policies and
• Improper conduct or unethical
• Danger to health and
• Damage to the
• Bribery
• Discrimination
• abuse or excessive use of

This is not an extensive list but merely provides examples of types of behaviours that may warrant a report.

5.3  What should not be reported through the Whistleblowing mechanism?

Complaints relating to personal circumstances in the workplace or to terms of employment (excluding the wrongful acts listed above) should not be reported under the Children’s Mission Anti-Corruption and Whistleblowing policy.

While Children’s Mission takes concerns relating to personal circumstances and terms of employment seriously, they should be raised with the appropriate authority handling such concerns, namely HR, by using the complaint procedure included within the Staff Handbook.

5.4  How to use the Whistleblowing Mechanism:

Whistleblowing can occur in writing or verbally, but it is advisable to do so via Children’s Mission website (https://barnmissionen.se/en/whistleblower-report/) where reports can also be made anonymously. It can also be done by sending an email to following address: whistleblowing@barnmissionen.se. The contact persons within Children’s Mission are two members of the Swedish Board appointed for this purpose. If the incident involves a partner organization in Africa, a board member from our regional office, Children’s Mission Africa, will also be contacted.

Children’s Mission encourages Whistle-blowers to provide as much detail about their concern/s as possible, however at the same time, it is noted that it is not the Whistle-blower’s role to investigate. Appendix I, entails what information that should be included in the report.

5.5  Confidentiality

Children’s Mission encourages both anonymous and open disclosures, however we note that investigations may be more difficult if there is a need to obtain further information in the case of an anonymous report.

While every effort will be made to keep a whistleblowers’ identity confidential, there may be circumstances in which it will be necessary to disclose an identity; this may occur in connection with associated disciplinary or legal investigations or proceedings.

5.6  Protection and Support for Whistleblowers

The Whistleblower Act (Law 2021:890) prohibits employers from any retaliations against those who report misconduct. It is understandable that Whistle-blowers are sometimes concerned about possible repercussions emanating out of the complaints or concerns lodged. Children’s Mission therefore aims to encourage openness and will support staff and others who raise genuine concerns under this policy, even if such concerns turn out to be of a mistaken nature.

No individual raising genuinely held concerns in good faith under this policy will be dismissed or be subject to any detrimental consequences arising from their actions such as unwarranted disciplinary action, victimisation, threats or other unfavourable treatment.

If any person/s is subjected to detriment as a result of making a disclosure, they should inform the appropriate authority immediately using the methods and channels as set out in this policy. If the matter is not remedied, they should raise it formally using Children’s Mission's complaint chain, detailed in staff manual.

CM Staff must not in any way threaten or retaliate against Whistle-blowers. If any member of staff is found to be guilty of such conduct, that staff member will be subject to disciplinary action.

5.7  False Allegations

Any false allegation/s which proves to have been made maliciously or with a view to personal gain will be viewed as a serious disciplinary offence and may result in disciplinary action.

6.  Responsibilities of Staff and Partners

All employees, volunteers, and partners must act in good faith and report any suspected or actual instances of corruption, unethical behavior, or violations of this policy. Staff are encouraged to adhere to procedures and safeguards to prevent corruption, such as following procurement guidelines, ensuring transparency in financial management, and making decisions based on merit. SBM management will ensure that all reports are handled in accordance with this policy, oversee investigations, and ensure corrective measures are implemented.

7.  Disciplinary Action

Any employee, volunteer, or partner found to have engaged in corrupt practices, fraud, or unethical behavior will face disciplinary action, which may include termination of employment, legal action, or both. Similarly, any individual who knowingly makes false or malicious reports will be subject to disciplinary action.

8.  Awareness and Training

Children’s Mission will provide training to all employees, volunteers, and partners on anti-corruption practices and the whistleblowing process. This training ensures that all stakeholders are aware of the organization's commitment to ethical conduct and the proper channels for reporting concerns. Children’s Mission will regularly communicate its commitment to anti-corruption and ethical conduct and ensure that all staff are aware of the whistleblowing policy and how to report concerns. Children’s Mission will also champion its commitment to a No Corrupt Generation.

9.  Monitoring and Review of Policy

The effectiveness of this policy will be reviewed regularly to ensure that it is being implemented effectively and that the organization maintains the highest standards of integrity and transparency.

This policy will be monitored and reviewed by the Board of Children’s Mission for its effectiveness and to ensure it aligns with changes in relevant laws, regulations, or organizational requirements. Helpline Contact Details: whistleblowing@barnmissionen.se

10.  Adoption

This policy was adopted by the CM Board in 2011 and revised on 2025-02-19 and 2026-04-09. It will be reviewed annually, or as needed, to ensure it remains relevant and effective.

Annex I: Process under the Whistleblower Act

Anti-corruption and Whistleblowing Policy
First adopted by the Board, 2011
Version: 2026-04-09