Delivering a Response to DFID's Code of Conduct V3
Supply partners must utilize the response template to demonstrate compliance with DFID's Code of Conduct. The template guides them in providing detailed information on each Key Performance Indicator (KPI) and ensuring accuracy in submissions. Partner compliance is crucial for maintaining high assurance levels. Non-compliance may trigger in-depth validation processes. Regular submissions and updates are required for ongoing contracts
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Presentation Transcript
Supply Partner Compliance Response Template Delivering a response to DFID s Code of Conduct V3 2019
Providing a Response to the Code What to expect Welcome to our Response Template Supply partners should use this response template to display compliance to each KPI in the DFID Supply Partner Code of Conduct. This response is your annual corporate level submission towards the Code and will be used to calculate your corporate spot check score. This response will be spot checked to provide our first level of assurance. Deep dive activity will assess content with more rigour and on a contract by contract basis to validate submission content, ensure policies / procedures provided are being adhered to, declarations are accurate etc. Omissions in your response may result in deep dive activity to validate an area of compliance. A further annual declaration is required to be submitted while live contracts are in place to reaffirm that the content within this response is up to date and accurate.
Supply Partner Response Dos & Donts Dos Don ts Delete slide 2 and this slide before saving Send multiple emails containing separate documents and parts of response Save this file as a .pdf document Embed files within this template Your compliance response submission should include this Response Template fully populated along with all supporting organisational documentation Reference policy / process / procedure in your response without submitting a physical copy for assessment Submit documents via one email in a zipped folder or via WeTransfer if the files are too large Refer to our Supply Partner Compliance Handbook for further detail and clarification on how to fully respond effectively to each KPI
KPI Slides How to Populate This area details the KPI number, priority area and the contractual KPI from the Code. This box provides brief guidance on what we expect you to provide as a minimum please note that this is not exhaustive to our checks. Please RAG rate ( Red, Amber, Green) your organisation against this KPI and mark as Complete if fully compliant or replace complete with the expected compliance date. Format: DD/MM/YYYY Populate this box with any points of discussion you have on this particular KPI or alternatively populate with N/A. Populate this box with commentary around how your organisation adheres to each KPI within the Code. This should include commentary as to what your organisation does in this area, referencing attached policy, procedure, declarations, etc. Populate this box with next steps you are taking to achieve full compliance to this KPI if applicable or alternatively populate with N/A. Please reference your attached documents in this box. This ensures that we can check the correct files which correspond to each KPI. Key = No Action Required = Populate E.g. 1 Finance Governance Policy.pdf
Organisational Declarations Slides 7 & 8
Supply Partner Declaration Code of Conduct Please delete this text and populate with your organisations declaration to adhere to the DFID Supply Partner Code of Conduct. Type company signatory name here Type job title of company signatory here
Supply Partner Declaration UN Global Compact Please delete this text and populate with your organisations declaration of your commitment to the UN Global Compact (UNGC) and the principles set out within. Type company signatory name here Type job title of company signatory here
Value for Money & Governance Standards Priority Area 1: Slides 9-11
KPI: Economic and governance policies in practice Value for Money & Governance Standards 1a) Complete KPI How does your organisation comply with this KPI? Guidance: Three years accounts, policies / process that display financial governance, policies / process that displays governance of quality (financial, product & service etc.) Text Areas for discussion with DFID Text Next steps to achieve full compliance Text Attachments Text
KPI: VfM being maximised over the life of a contract: 1. By confirmation of annual profit level fluctuations since tender submittal 2. by timely identification and resolution of issues 3. ensuring lessons learned are shared Value for Money & Governance Standards 1b) KPI DD/MM/YYY How does your organisation comply with this KPI? Guidance: Evidence of proactively managing VfM (e.g. Value for Money Statement, contract management processes), commitment to open book accounting including process, commitment to profit reporting & profit on contract displayed. Text Areas for discussion with DFID Text Next steps to achieve full compliance Text Attachments Text
KPI: Tax Declaration (HMRC format) Tax the organisation paid on profits made in the last 3 years, and in which countries Compliance with relevant country level tax regulations fully understood and met Value for Money & Governance Standards 1c) KPI DD/MM/YYY How does your organisation comply with this KPI? Guidance: HMRC tax certification, declaration that organisation adheres to tax regulations in all territories operating within, declaration on behalf of all supply partners that they adhere to tax regulations. (e.g. statements of assurance, certificates, due diligence processes etc.) Text Areas for discussion with DFID Text Next steps to achieve full compliance Text Attachments Text
Ethical Behaviour Priority Area 2: Slides 13-18
KPI: Recruitment policy (which must address circumstances where there may be potential or actual conflict of interest) Ethical Behaviour 2a) KPI RAG How does your organisation comply with this KPI? Guidance: Provision of a recruitment policy, due diligence of staff (are they suitably qualified, trained and vetted), ethical recruitment processes, supply partner recruitment processes etc. Text Areas for discussion with DFID Text Next steps to achieve full compliance Text Attachments Text
KPI: Ongoing conflict of interest(COI) mitigation and management Ethical Behaviour 2b) KPI RAG How does your organisation comply with this KPI? Guidance: Provision of a Conflict of Interest policy, robust processes to avoid COI, COI trackers Text Areas for discussion with DFID Text Next steps to achieve full compliance Text Attachments Text
KPI: Refresher ethical training and staff updates (including disclosure restrictions on DFID confidential information) Ethical Behaviour 2c) KPI RAG How does your organisation comply with this KPI? Guidance: Ethical training provided to staff and delivery chain also conducting sufficient training, training logs for staff completion, access to learning systems, documents, processes, ethical training policies, annual declarations / proof of recurring / update training etc. Text Areas for discussion with DFID Text Next steps to achieve full compliance Text Attachments Text
KPI: A workforce Whistleblowing Policy Ethical Behaviour 2d) KPI RAG How does your organisation comply with this KPI? Guidance: Provision of a Whistleblowing Policy, process, procedure, evidence of continuous workforce awareness being maintained, evidence of whistleblowing mechanisms in place Text Areas for discussion with DFID Text Next steps to achieve full compliance Text Attachments Text
KPI: 1. Procedures for staff involved in DFID funded business to immediately report suspicions or allegations of aid diversion, fraud, money laundering or counter terrorism finance to DfID s Internal Audit Investigations Section (IAIS) ( previously Counter Fraud & Whisitleblowing Unit CFWU) at reportingconcerns@dfid.gov.uk or on +44(0)1355 843747 2. Employees working on DFID Contracts fully aware of the DFID external website reporting concerns mailbox Ethical Behaviour 2e) KPI RAG Guidance: Provision of fraud avoidance policy, process, procedure, evidence of continuous awareness of how to report allegations, evidence of procedures in place to avoid fraud/ money laundering, evidence of circulating reporting concerns mailbox / telephone number to all staff within the organisation How does your organisation comply with this KPI? Text Areas for discussion with DFID Text Next steps to achieve full compliance Text Attachments Text
KPI: Declarations of direct or subcontractor staff members proposed to work on DFID funded business if employed by DFID or the Crown in the preceding two years. Supply Partners and their subcontractors must provide proof of compliance with the HMG approval requirements under the business appointment rules. Ethical Behaviour 2f) KPI RAG How does your organisation comply with this KPI? Guidance: Assurance provided that no direct or sub- contracted staff have been employed by the Crown in past two years or, where they have, proof of HMG approvals declaration must be provided and rules followed Text Areas for discussion with DFID Text Next steps to achieve full compliance Text Attachments Text
Transparency & Delivery Chain Management Priority Area 3: 20-25
Transparency & Delivery Chain Management KPI: International Aid Transparency initiative (IATI) compliance for Supply Partner and delivery chain Supply Partners 3a) KPI RAG Guidance: Commitment to IATI reporting as an organisation, confirmation of IATI registration, project data uploaded to IATI in required format, provision of IATI identifiers for all DfID projects / programmes, Declaration of IATI registration and upload for downstream supply partners Areas for discussion with DFID How does your organisation comply with this KPI? Text Text Next steps to achieve full compliance Text Attachments Text
Transparency & Delivery Chain Management KPI: Up to date and accurate records of all delivery chain Supply Partners 3b) KPI RAG How does your organisation comply with this KPI? Guidance: Commitment to delivery chain mapping, provision of delivery chain map for each project, documentation submitted in accordance with clause 28.7, Text Areas for discussion with DFID Text Next steps to achieve full compliance Text Attachments Text
Transparency & Delivery Chain Management KPI: Policies and practices for the management of delivery chain partners and affiliates aligned to the DFID Supply Partner Code of Conduct 3c) KPI RAG How does your organisation comply with this KPI? Guidance: Provision of supply chain management policies, processes, procedures etc. Contract management processes provided, evidence of policies put in practice Text Areas for discussion with DFID Text Next steps to achieve full compliance Text Attachments Text
Transparency & Delivery Chain Management KPI: Tax evasion, bribery, corruption and fraud statements of assurance provided 3d) KPI RAG How does your organisation comply with this KPI? Guidance: Provision of fraud, bribery & anti corruption policies, processes, procedures, demonstration of commitment to DFID standards in these areas, statements of assurance provided for organisation and on behalf of downstream partners Text Areas for discussion with DFID Text Next steps to achieve full compliance Text Attachments Text
Transparency & Delivery Chain Management KPI: All delivery chain partner employees working on DFID Contracts fully aware of the DFID reporting concerns mailbox 3e) KPI RAG How does your organisation comply with this KPI? Guidance: Evidence that reporting concerns details and process have been circulated to all downstream partners, commitment to ensuring awareness via policy, process, procedure Text Areas for discussion with DFID Text Next steps to achieve full compliance Text Attachments Text
Transparency & Delivery Chain Management KPI: HMG prompt payment policy adhered to by all delivery chain partners 3f) KPI RAG How does your organisation comply with this KPI? Guidance: Declaration of commitment to HMG Prompt Payment Code provided, declaration on behalf of delivery chain partners provided, evidence of adherence provided Text Areas for discussion with DFID Text Next steps to achieve full compliance Text Attachments Text
Environmental Issues Priority Area 4: Slides 27 & 28
KPI: 1.Steps in place to identify environmental risks (e.g. by maintaining a risk register) Ensuring legislative requirements are being met 2. Formal context specific environmental safeguarding policies in place to ensure legislative requirements are being met 4a) Environmental Issues KPI RAG How does your organisation comply with this KPI? Guidance: Provision of Environmental safeguarding policy, process, procedures, commitment to environmental practices, adherence to international laws and standard, provision of environmental risk registers etc. Text Areas for discussion with DFID Text Next steps to achieve full compliance Text Attachments Text
KPI: Published annual environmental performance reports 4b) Environmental Issues KPI RAG How does your organisation comply with this KPI? Guidance: Provision of any formally published environmental performance reporting, evidence of environmental performance monitoring etc Text Areas for discussion with DFID Text Next steps to achieve full compliance Text Attachments Text
Terrorism & Security Priority Area 5: Slides 32-35
KPI: Up to date status declaration regarding the reporting of terrorist offences or offences linked to terrorist activities or financing 5a) Terrorism & Security KPI RAG How does your organisation comply with this KPI? Guidance: Provision of any anti-terrorism / security policy, provision of declaration that no employees are engaged in terrorist activity, no known terrorist funding taking place, Text Areas for discussion with DFID Text Next steps to achieve full compliance Text Attachments Text
KPI: no persons working on contract on prescribed terrorist lists (includes provision of declaration on behalf of downstream supply partners) 5b) Terrorism & Security KPI RAG How does your organisation comply with this KPI? Guidance: Due diligence procedures provided and in place for mitigation of terrorism / security risk e.g. staff vetting, supply partner checks for terrorism, due diligence of supply chains etc. Certification at or above the level set out in the tender submittal (SQ) Text Areas for discussion with DFID Text Next steps to achieve full compliance Text Attachments Text
KPI: Data managed in accordance with DFID Security Policy and systems in accordance with the HMG Cyber Essentials Scheme 5c) Terrorism & Security KPI RAG How does your organisation comply with this KPI? Guidance: Provision of digital strategy / data security policy, Evidence of data being managed in accordance with DFID Security Policy and systems in line with HMG Cyber Essentials Scheme, certification provided, GDPR policy inclusion evidenced etc Text Areas for discussion with DFID Text Next steps to achieve full compliance Text Attachments Text
KPI: Best practice global Principles for Digital Development in place and adhered to 5d) Terrorism & Security KPI RAG How does your organisation comply with this KPI? Guidance: Declaration of adherence to Global Principles for Digital Development, formal endorsement of principles / listing on website, commitment to work under principles etc. Text Areas for discussion with DFID Text Next steps to achieve full compliance Text Attachments Text
Safeguarding, Social Responsibility & Human Rights Priority Area 6: Slides 35-38
Safeguarding, Social Responsibility & Human Rights KPI: Provision of a current internal document demonstrating good practice and assuring compliance with key legislation on international principles on labour and ethical employment ( including Modern Day Slavery Act 2015 compliance) 6a) KPI RAG How does your organisation comply with this KPI? Guidance: Membership of UNGC, evidence of policy, procedure, process encouraging international principles on labour and ethical employment, statement / policy on Modern Slavery, optional completion of cross government Modern Slavery Assessment, Text Areas for discussion with DFID Text Next steps to achieve full compliance Text Attachments Text
Safeguarding, Social Responsibility & Human Rights KPI: Organisational procedures in place directly and within the delivery chain 1. to prevent actual, attempted or threatened sexual exploitation or abuse or other forms of inequality or discrimination by employees or any other persons engaged and controlled by the Supply Partner to perform any activities relating to DFID funded work. 2. For reporting suspected misconduct, illegal acts or failures to investigate actual attempted or threatened sexual exploitation or abuse . 6b) KPI RAG Guidance: Safeguarding policy provided, evidence of safeguarding procedures in place, clear method for reporting safeguarding concerns, declaration that no forms of abuse or harm are taking place within organisation/downstream partner organisations. Cases reported including no. of/ outcome, due diligence process evidenced. Robust procedures for reporting suspected misconduct, illegal acts or failures to investigate in place Areas for discussion with DFID How does your organisation comply with this KPI? Text Text Next steps to achieve full compliance Text Attachments Text
Safeguarding, Social Responsibility & Human Rights KPI: UN Global Compact membership in place Membership of Ethical Trading Initiative (ETI) optional 6c) KPI RAG How does your organisation comply with this KPI? Guidance: Declaration to adhere to UNGC principles 1&2 provided, evidence of how organisation adheres to principles 1&2, formal recognition of ILO standards Text ETI Membership would be considered positively in terms of organisational human rights due diligence but this is not a Code requirement Areas for discussion with DFID Text Next steps to achieve full compliance Text Attachments Text
Safeguarding, Social Responsibility & Human Rights KPI: 1.Principles cascaded to employees and delivery chain partners via an internal policy or written outline of good practice service delivery approaches to Human Rights and Safeguarding reflecting UN Global Compact Principles 1 & 2 2. Number and details of any organisational safeguarding allegations reported 3.Level of commitment in relation to the Contract evident in delivery practices in line with the workplace and community guidance provided in the DFID Supply Partner Code of Conduct Annex 2 6d) KPI RAG Guidance: Declaration / commitment of ensuring UNGC principles 1&2 adhered to by all staff and delivery chain partners, policy cascading principles to all staff evidenced. Safeguarding allegations report sample provided Declaration about how the organisation is ensuring workplace and community human rights protective action and how this is taking place in practice with downstream partners in line with the Code Areas for discussion with DFID How does your organisation comply with this KPI? Text Text Next steps to achieve full compliance Text Attachments Text
