Financial Integrity

Our books and records must accurately and fairly reflect our transactions in sufficient detail and in accordance with our accounting practices and policies. Some employees have special responsibilities in this area, but all of us contribute to the process of recording operational results or maintaining records.

Our Core Value of Accountability reflects our commitment to ensure that we are financially responsible:

• We are fiscally responsible.
• We hold ourselves and our colleagues responsible for the outcomes of our choices, behaviors and actions.
• We take responsibility for all outcomes, positive and negative.

Our Core Value of Integrity reflects our commitment to ensure that we are financially responsible:

• We are honest, fair and transparent with our Winrock colleagues, our partners and funders, and all who benefit from our work.

Business Records

The accuracy and completeness of our disclosures and business records is essential to making informed decisions and to ensure accountability to our funders, regulators and others. Ensure that the information you record is accurate, timely and complete, and maintained in a manner that is consistent with our internal controls, disclosure controls and our legal obligations.

Take Action:

• Create records that accurately reflect the truth of the underlying event or transaction. Be guided by the principles of transparency and truthfulness.
• Write carefully in all of your business communications. Write as though someday the records you create may become public documents.
• Watch out for records that are not clear and complete, or that obscure the true nature of any action.
• Watch out for undisclosed or unrecorded funds, assets or liabilities.
• Watch out for improper destruction of documents. Follow the Record Management policy in this Code.

Accounting Practices

All payments and transactions must be properly authorized in accordance with Winrock operating procedures and Delegations of Authority, and fully and accurately recorded in Winrock’s books and records.

All payments and transactions must follow all applicable laws, requirements of Winrock donors and funders and established accounting policies.

Winrock will not tolerate dishonesty, including false recordkeeping.

Take Action:

• Never issue incorrect, incomplete or inexact information, or information which could confuse the person who receives it.
• Never rationalize or even consider making false representations or falsifying records.
• If you are aware of or suspect false recordkeeping or representations by others, you must report such activities immediately using the channels described in the beginning of this Code.  

Prohibited Conduct Examples:

• Making payments for Winrock without supporting documentation or for a purpose contrary to that described in supporting documentation
• Establishing undisclosed or unrecorded Winrock funds or assets
• Making false or misleading entries in, or omitting important information from, Winrock records
• Manipulating bookings for the purpose of affecting a specific financial reporting period
• Documents should only be disposed of in compliance with Winrock’s Record Management Policy, and should never be destroyed or hidden.
• Never destroy documents in response to or in anticipation of an investigation or audit.
• More information on Winrock’s accounting policy can be found here, and the Project Finance Manual can be found here.

Anti-Corruption and Bribery

All forms of bribery, kickbacks, and other corrupt practices are prohibited regardless of local customs. Winrock is committed to complying with all applicable anti-corruption laws.

Winrock does not pay bribes, kickbacks or facilitation payments at any time for any reason. This includes to government officials as well as non-government officials. This applies equally to any person or firm who represents Winrock. The only possible exception is if a potentially improper payment is necessary to protect an individual’s health or safety. In such a situation, you should immediately report the payment to the Chief Risk and Compliance Officer.

Winrock staff are not permitted to request, solicit, or accept cash or fund transfers from beneficiaries or partners for program activities. All program monetary activity should flow through Winrock’s bank accounts.

Key Definitions

Corruption is the abuse of an entrusted power for private gain.

Bribery means giving or receiving anything of value (or offering to do so) to obtain business or a financial or commercial advantage.

Kickbacks are payments made with the intent to influence or gain something from a company or person.

Facilitation payments are typically small payments to a low-level government official that are intended to encourage the official to perform his responsibilities.

Third Parties Acting on Behalf of Winrock

It is especially important that we exercise due diligence and carefully monitor third parties acting on our behalf.  

We carefully screen all third parties, including suppliers, consultants, and vendors who work on Winrock’s behalf, particularly when dealing in countries with high corruption rates and in any situations where “red flags” indicate further screening is needed before retaining the third party.

Third parties must understand that they are required to operate in strict compliance with our standards and to maintain accurate records of all transactions.

Anti-Money Laundering/Anti-Terrorist Financing

Money laundering is a global problem with far-reaching and profound consequences. It is defined as the process of converting illegal proceeds so that funds are made to appear legitimate, and it is not limited to cash transactions. 

Involvement in such activities undermines Winrock’s integrity, damages our reputation and can expose our organization and the individuals involved to severe sanctions. Winrock must screen employees and its vendors and partners to ensure that individuals and companies are not sanctioned. Immediately report any suspicious financial transactions and activities to the Chief Risk and Compliance Officer and, as required, to appropriate government agencies.

Antitrust and Fair Competition

Winrock believes in free and open competition and will not engage in improper practices that may limit competition. We never look to gain competitive advantages through unethical or illegal business practices.

Antitrust laws are complex, and compliance requirements can vary depending on the circumstances, but in general, the following activities must be avoided and, if detected, reported to the Chief Risk and Compliance Officer: 

• Sharing Winrock’s competitively sensitive information or that of our funders with a competitor
• Sharing competitively sensitive information of business partners or other third parties with their competitors
• Attempting to obtain non-public information about competitors from new hires or candidates for employment
• Engaging in conversations about competitively sensitive information with colleagues or competing organizations
• Collusion—when organizations secretly communicate or agree on how they will compete. This could include agreements or exchanges of information on supplier pricing, terms or wages.
• Bid-rigging—when competitors or service providers manipulate bidding so that fair competition is limited. This may include comparing bids, agreeing to refrain from bidding or knowingly submitting noncompetitive bids.
• See Winrock’s Procurement Policy for more information.

Global Trade

All employees, officers and directors must strictly comply with laws that govern our operations including the import, export and re-export of technology. Any violation of these laws, even without knowledge, could have damaging and long-lasting effects on our business.

Watch Out:

• Transferring technical data and technology to someone in another country, such as through email, conversations, meetings or database access. This restriction applies to sharing information with some coworkers, as well as non-employees.

Supplier, Vendor, or Consultant Relations and Purchasing

Winrock evaluates and engages with qualified suppliers, vendors, and consultants or contractors on an objective basis, grounded in fairness. When selecting suppliers, we assess each supplier’s ability to satisfy our organizational and technical needs and requirements.

We make procurement and purchasing decisions based on the long-term cost and benefit to Winrock. All agreements are negotiated in good faith and must be fair and reasonable for both parties.

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