This Due Diligence Policy document was approved by the Gambian Community Birmingham (herein referred to interchangeably as GCB or charity) Trustees on 13th December 2021, following an Executive Committee Meeting. This Policy intertwines with our ethical values as indicated in our Volunteer Code of Conduct and Responsible Practices during our interactions and relationships with external partners, i.e., donors, contractors, and suppliers.

In a global context with an increasingly demanding legal framework as regards responsibility of Charities towards preventing corrupt practices in their relations, approval of this Policy shows not only compliance with certain statutes, such as UK Charities Act 2011and various enactments (2006 and 1993) and Bribery Act 2010), but also aligning our relations with our potential future development partners, contractors, suppliers, and individual members.

Scope of Application:
This Policy shall apply to the GCB trustees and binding for the entire staff and volunteers, regardless of position. The enforcement of this Policy, either in full or in part, may extend to any natural and/or legal person associated with the charity on any terms other than an employment relationship, where this is practicable on account of the nature of the relationship and may be appropriate to meet its purpose. Under this Policy, the GCB may develop procedures and instructions to implement and enforce the obligation(s) undertaken, and to bring it into line with local laws and regulations applicable to charity operations. The process to identify and review partners, contractors and suppliers engaged in relations with the GCB, in the field of corruption, fraud, international sanctions or similar risks, and its implementing regulations, is independent –although they may be contemporaneously carried out to ensure its charitable integrity is upheld.

Overarching Principles:
This Policy will be developed and implemented based upon the following principles:

• The GCB shall identify and review all its donor Partners, contractors, suppliers, and
• Third Parties with whom it has (or will have) relations, around charitable activities, i.e., putting forward a fully budgeted and need based project proposal.
• Due Diligence processes shall be performed based upon reasonableness and proportionality principles and shall have different levels based upon the association of Third Parties with the charity for the risk of influence, reputational damage or otherwise.
• GCB shall not engage agencies, organisations and or individuals in soliciting donations towards its charitable objects who have not been identified and reviewed pursuant to this Policy and its implementation.
• GCB shall not have relations with any Third Party that its assessment detects risk without an Action Plan to remedy or mitigate them having been put in place.
• Upon carrying out any Due Diligence process, the GCB will not delay establishing a business relationship.

Means to implement Due Diligence:

The GCB shall employ any available means to carry out an appropriate Due Diligence process, including:

• Recommendations from reputable sources
• Compliance databases
• Financial viability (contractors)

Disclosure of the Policy:
This Policy will be available to all trustees, stakeholders and placed on the GCB website. Likewise, the Policy shall be subject to the appropriate disclosure, training, and awarenessraising, aimed at its full understanding and enforcement.

Implementation of the Policy:
The GCB trustees undertake full and effective implementation of the Policy. It shall carry out appropriate processes for the regular identification of current and potential impacts prior to approaching potential funders during the resources mobilisation process and take the relevant measures to prevent and mitigate any potential negative consequences to the charity. Likewise, the GCB will collaborate with relevant stakeholders in the implementation of this Policy. The Chairman shall be responsible for implementing and monitoring the Policy as a control mechanism, with the required collaboration of all trustees and any other institution directly associated with a Third Party. The Internal Audit shall be responsible for overseeing the Policy.

Update and Review of the Policy:
The Policy will be reviewed and updated, where applicable, to bring it into line with any changes that the GCB may undergo, or that may occur in the context where it operates, always ensuring its effective implementation.

Adopted on the ………………………………….