Report fraud or abuse

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Unitaid has zero tolerance for acts of wrongdoing in projects which it funds.

Wrongdoing includes fraud, bribery, corruption, misappropriation, and sexual exploitation and abuse, among other types of unethical or dishonest behaviours. A permanent hotline, the Integrity Hotline, has been established to make it easier for you to come forward and report your concerns. You may choose to make a report anonymously. Please alert us immediately if you believe that wrongdoing has occurred or is occurring within a Unitaid -funded project. Your help in identifying and reporting any wrongdoing that has come to your attention is really important to us. Wrongful acts take resources away from Unitaid’s objectives of improving access to treatments and diagnostics for HIV/AIDS, malaria and tuberculosis, as well as other diseases, in low- and middle-income countries.

Further information on using the Integrity Hotline and the types of wrongdoing which should be reported is set out below.

What should you report?

If you suspect that wrongdoing may have occurred or is occurring in a Unitaid-funded project, you should report it. The following list gives an indication of the types of wrongdoing that should be reported, but is not exhaustive:

  • Human rights violations within Unitaid-funded projects
  • Sexual exploitation or abuse
  • Abuses of power, authority or position for personal gain
  • Harassment or bullying
  • Unethical behaviour in clinical research (such as failure to obtain informed consent or enforce relevant clinical practice standards)
  • Failure to maintain medical confidentiality
  • Any incident creating a substantial and specific danger to public health or safety
  • Stealing money, medicine or equipment
  • Fake invoicing
  • Using grant money for personal use
  • Wastage of resources
  • Staging of fake training events or conferences
  • Unnecessary or excessive travel
  • Irregularities in tender processes (such as fraudulent bids, bid collusion, bid manipulation, coercive practices, etc.)
  • Misappropriation of assets
  • Counterfeiting drugs
  • Bribery and payment of kickbacks
  • Unreported and/or unmanaged conflicts of interest
  • Sabotage
  • Any other acts of unethical behaviour or misconduct

Who can report suspected wrongdoing?

All Unitaid stakeholders, including employees, grant recipients and Project Country beneficiaries of Unitaid grants should report wrongdoing occurring in Unitaid-funded projects. Anyone else who is aware of such wrongdoing is also strongly encouraged to report.

How can you report?

Grantees with a grant agreement in place with Unitaid can either use the standard fraud and abuse reporting templates indicated in their grant agreements or the Integrity Hotline if they wish to remain anonymous. Other stakeholders or interested persons may use the Integrity Hotline. The matter will be referred for review by the Office of Internal Oversight Services of the World Health Organization (WHO), which will make a determination on the appropriate response to the report, including whether to conduct an investigation.

How can you report through the Integrity Hotline?

You can contact the Integrity Hotline confidentially, and anonymously if desired, by telephone or through an online form. Details for both options, including a list of telephone numbers by country, are found on the following website: https://www.who.int/about/ethics/integrity-hotline. When submitting a report using the online reporting form, please select WHO as the entity being reported and then specify Unitaid in the details of your report.

Who administers the Integrity Hotline?

The hotline service is provided by NAVEX Global, a professional, independent organization with impartial staff trained to handle these types of reports.

NAVEX Global handles reporting of issues involving WHO and WHO’s hosted partnerships such as Unitaid.

What information should you include?

Substantiating your report with responses to the following questions will facilitate the management of the case:

  • What alleged wrongdoing you are reporting?
  • What happened exactly? Please describe in detail.
  • Who committed the alleged wrongdoing? Was anyone else involved? Provide full names and titles if possible.
  • Where and when did it take place? Provide location(s), dates and times, if possible.
  • How did you become aware of the incident?
  • Who else knows?
  • Why do you believe the activity was improper?
  • Do you have any other relevant information?

What happens next?

The information you give will be passed on to WHO’s Office of Internal Oversight Services, who will act on it while safeguarding confidentiality throughout the process to the greatest extent possible and in accordance with the WHO Policy on Preventing and Addressing Retaliation (found at http://www.who.int/about/ethics/en/). If you choose to make a report anonymously, after submitting your report, you will be given a unique reference number, which will facilitate future interactions with the Integrity Hotline and/or investigators regarding your report. .

If you require guidance or fear retaliation, the WHO Ethics Office offers confidential and impartial advice and support on how to handle the situation. The WHO Ethics Office can be contacted using the following confidential email address ethicsoffice@who.int.

Anonymity and confidentiality

Whichever method you decide to use to submit your report to the Integrity Hotline, rest assured that you can remain totally anonymous if you wish. When you submit your report through the online reporting form, the information will be forwarded to NAVEX Global in an encrypted format. We will not attempt to trace your details at any time, and should you volunteer your personal details, they will not be passed to WHO or Unitaid unless you give your consent to do so.

Remember that the more information you provide, the more likely it is that WHO/Unitaid can satisfactorily resolve the incident. This is particularly so if you have chosen to remain anonymous, as your report will only be reviewable if independent and substantiated data can corroborate the information you have shared.

Confidentiality is very important to us. When reports are received through the Integrity Hotline, confidentiality will be safeguarded throughout the process to the greatest extent possible and in accordance with the WHO Policy on Preventing and Addressing Retaliation, found at http://www.who.int/about/ethics/en/.

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