arrow's anti-corruption policy and sexual harassment policy

Arrow’s Anti-Corruption Policy

The purpose of the Anti-Corruption Policy is to support ethics of work which are characterised by a high personal and organisational integrity, both internally and in relation to partners and donors. ARROW receives funding from many different sources and donors, and we have a responsibility to administer this funding in a responsible manner. The regulations of ARROW make clear demands to prevent and fight corruption, and we will fulfil this responsibility by promoting transparency and democratic control within our own organisation and our partner organisations.

The anti-corruption policy applies to all staff, the Board of Directors of ARROW, the Programme Advisory Committee (PAC) of ARROW, and ARROW partners. Everyone mentioned above is required to follow this anti-corruption policy, and any infringement of this policy will be treated in accordance with the rules for follow-up and reporting described in this document.

Corruption is a threat against good governance, sustainable development, democratic processes and good business practice and contributes to social inequality. ARROW is at all times responsible towards our donors, cooperating partners and target groups, and prevention of corruption is crucial for the development results that we wish to achieve in our work.

ARROW works in developing countries in complex contexts with various languages and cultures and recognises that we and our partners must be able to carry out our work within these differences. This makes big demands on all to maintain and promote a high ethical standard and responsible behaviour built on knowledge, respect and common sense. We also follow the national legislation where we work and observe the rules and regulations of international law.

To report a suspected case of corruption, please write to the Anti-Corruption Committee at or Fax: 603-22739913 or send it by mail to us.

ARROW will consider anonymous complaints if there is enough information in the complaint to enable us to make further enquiries. If, however, an anonymous complaint does not provide enough information to enable us to take further action, we may decide not to pursue it further. Any decision not to pursue an anonymous complaint must be authorised by the anti-corruption committee.


Arrow’s Sexual Harassment Policy

Policy Statement:

The Asia Pacific Resource and Research Centre (ARROW) is committed to providing a safe environment for all its Staff, Board Members, PAC Members, Donors, Partners, Vendors, Participants, Consultants and stakeholders free from discrimination on any ground and from harassment at work including sexual harassment. ARROW will operate a zero-tolerance policy for any form of sexual harassment in the workplace, treat all incidents seriously and promptly investigate all allegations of sexual harassment. Any person found to have sexually harassed another will face disciplinary action, up to and including dismissal from employment. All complaints of sexual harassment will be taken seriously and treated with respect and in confidence. No one will be victimised for making such a complaint.

Purpose of Policy:

Our sexual harassment policy aims to protect all staff, Board members, PAC Members, Donors, Partners, Vendors, Participants, Consultants, Stakeholders in ARROW from unwanted sexual advances and give them guidelines to report incidents including alleged digital harassment. We will also explain how we handle claims, address sexual harassment as per the National Laws of the country and help victims recover. We won’t tolerate sexual harassment in our workplace in any shape or form. Our culture is based on mutual respect and collaboration. Sexual harassment is a serious violation of those principles.

Scope of Policy:

This policy applies to all ARROW Staff, Board members, PAC Members, Donors, Partners, Vendors, Consultants, Stakeholders and Participants of ARROW organised or supported events.


What is sexual harassment?

Sexual Harassment is broadly defined as any solicitation of sexual favours of unwanted imposition of any sexually related activity. Anyone can be a victim of sexual harassment, regardless of their sex and of the sex of the harasser. ARROW recognises that sexual harassment may also occur between people of the same sex. What matters is that the sexual conduct is unwanted and unwelcome by the person against whom the conduct is directed.

ARROW recognises that sexual harassment is a manifestation of power relationships and often occurs within unequal relationships in the workplace, for example between manager or supervisor and employee. Sexual Harassment is prohibited whether it takes place within ARROW premises or outside, including at social events, interventions, training sessions or conferences organised or supported by ARROW.

Sexual harassment can involve one or more incidents and actions constituting harassment which may be physical, verbal and non-verbal, via electronic modes of communication (digital), virtual workspaces, virtual meetings, social media etc.

Examples of conduct or behaviour which constitute sexual harassment include, but are not limited to:

Physical conduct

Verbal conduct

Non-verbal conduct


ARROW recognises that sexual harassment may occur in unequal relationships (i.e. between a supervisor and his/her employee) and that it may not be possible for the employee to inform the alleged harasser. If an employee cannot directly approach an alleged harasser, he/she can approach HR staff or staff representative who are responsible for receiving complaints of sexual harassment.

HR staff or the staff representative will need to:

Throughout the complaints procedure and after, an employee is entitled to be helped by a counsellor within or outside of our organisation. For external assistance of counselling, please contact AWAM Telenita Helpline at 03-78770224. ARROW will nominate a small number of counsellors and provide them with special training to enable them to assist victims of sexual harassment. ARROW recognises that because sexual harassment often occurs in unequal relationships within the workplace, victims often feel that they cannot come forward. ARROW understands the need to support victims in making complaints.

Set up of an Independent Committee

Upon receipt of the alleged claims via the complaint form, an Independent committee of 3 members will be set up by the Operations & HR Officer with nomination of an independent member (staff) from the Executive Director. Two of the members shall be the elected Staff Representative and one Board member. This Independent committee will investigate the alleged claims and hold the required Inquiry, assisted and facilitated by the Operations and HR officer.

As per Section 81A, the HR department must proceed with preliminary investigation within 30 days from the date of receiving the complaint. Outcome of the investigation must be notified to the complainant or the employee(victim).

If the findings from the investigation shows no substantial evidence, then the HR department shall notify the victim in writing and keep in file the records of the investigation for future reference, in the event the victim makes a follow up complaint of similar nature.

However, if the findings justify that such act indeed is proven based on evidence adduced from the investigation and the inquiry, the HR department shall proceed with the disciplinary action to curb and deter such further incidents from happening. Such prompt action will also provide greater trust and confidence for the alleged victim to carry out her work without any worries, fear or emotional instability

Procedures by the HR department after Independent Committee’s recommendations

 Anyone who has been found to have sexually harassed another person under the terms of this policy is liable to any of the following sanctions by the Independent Committee and endorsed by the ED:

The nature of the sanctions will depend on the gravity and extent of the harassment. Suitable deterrent sanctions will be applied to ensure that incidents of sexual harassment are not treated as trivial.


Any communication or information gathered in any case is confidential except to the extent that disclosure is necessary to effectively implement this policy or to undertake any disciplinary or remedial steps arising from a complaint made under this policy. The details of the alleged case will be kept in strict confidence and filed in the Executive Director’s office.

False Accusations

A complaint made in bad faith shall constitute grounds for disciplinary action against the complainant, which shall be commenced in accordance with a disciplinary process. A bad faith complaint is a complaint that is made with a conscious design to mislead or deceive, or with a malicious or fraudulent intent.

Disciplinary Measures, Restitution and Appeal

ARROW treats harassment as misconduct and the Disciplinary Procedures of ARROW shall apply. If the investigation reveals evidence to support the complaint and it is upheld, the harasser will be disciplined in accordance with the Disciplinary Procedures. The nature and severity of the disciplinary measures will commensurate with the gravity of the harassment. Such measures may therefore include suspension or dismissal. The incident will also be documented in the harasser’s file.


Complaint form in ANNEXES section: APPENDIX A

Implementation of this policy

ARROW will ensure that this policy is widely disseminated to all relevant persons listed in the scope of this Policy. It will be included in the staff handbook. All new employees must be trained on the content of this policy as part of their induction into the company. Every year, ARROW will require all employees to attend a refresher training course on the content of this policy. It is the responsibility of every manager to ensure that all his/her employees are aware of the policy.

Monitoring and evaluation

ARROW recognises the importance of monitoring this sexual harassment policy and will ensure that it anonymously collects statistics and data as to how it is used and whether or not it is effective. Supervisors, managers and those responsible for dealing with sexual harassment cases will report on compliance with this policy, including the number of incidents, how they were dealt with, and any recommendations made. This will be done on a yearly basis. As a result of this report, the company will evaluate the effectiveness of this policy and make any changes needed.

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