UNEP integrity, fraud and corruption

The United Nations Core Values—integrity, professionalism and respect for diversity—are shared principles and beliefs that underpin the work of UNEP and guide the actions and behaviour of personnel.

UNEP personnel are required to

Become acquainted and comply with the relevant policies, rules and regulations,
Demonstrate zero tolerance for prohibited conduct by themselves and others,
Raise awareness and take action if they witness prohibited conduct, for example, by reporting prohibited conduct, and
Undertake relevant mandatory and non-mandatory training.

Prohibited conduct

Prohibited conduct refers to a staff member’s failure to comply with United Nations regulations, rules and internal policies.

The following United Nations rules, regulations and administrative issuances address prohibited conduct:

Acts that constitute prohibited conduct include, but are not limited, to the following:

Sexual harassment, Sexual exploitation and abuse
Harassment: Harassment is any unwelcome conduct that might reasonably be expected or perceived to cause offence or humiliation to another person when such conduct interferes with work or creates an intimidating, hostile or offensive work environment. Harassment may take the form of words, gestures or actions intended to annoy, alarm, abuse, demean, intimidate, belittle, humiliate or embarrass another.
Discrimination: Discrimination is any unfair treatment or arbitrary distinction based on a person’s race, sex, gender, sexual orientation, gender identity, gender expression, religion, nationality, ethnic origin, disability, age, language, social origin or other similar shared characteristic or trait.
Fraud and corruption: Fraud encompasses any act or omission whereby an individual or entity knowingly misrepresents or conceals a material fact in order to obtain an undue benefit or advantage for himself, herself, itself or a third party, or to cause another to act to his or her detriment. Corruption refers to any act or omission that misuses official authority or seeks to influence the misuse of official authority in order to obtain an undue benefit for oneself or a third party. Fraudulent acts are any intentional misconduct that misleads, or attempts to mislead, a party to obtain a financial benefit or other benefit or to avoid an obligation and seek to evade detection.
Abuse of authority: Abuse of authority is the improper use of a position of influence, power or authority against another person. This is particularly serious when a person uses their influence, power or authority to improperly influence the career or employment conditions of another, including, but not limited to, appointment, assignment, contract renewal, performance evaluation, working conditions or promotion.
Other prohibited conduct includes unauthorised outside activities, misrepresentation, forgery, false certification or failure to disclose a material fact in connection with United Nations claims and benefits, acts or omissions in conflict with the general obligations of a staff member, misuse of United Nationsvproperty, medical and dental fraud, and misuse of office, including breach of confidentiality and abuse of privileges and immunities.

Reporting prohibited conduct

Information about possible prohibited conduct may be brought to the attention of the Office of Internal Oversight Services (OIOS) Investigation hotline or the Executive Director of UNEP (with a copy to OIOS). A formal report should be detailed enough to allow for a review of the report.

All anonymous reports should be filed with OIOS.

All reports of possible prohibited conduct are reviewed through a preliminary assessment to decide on the need for an investigation. OIOS, or UNEP, investigates reports of possible prohibited conduct through fact-finding panels, which are set up to make findings of fact that will help others determine whether prohibited conduct took place. A disciplinary process is conducted, following which disciplinary measures are implemented.

Procedure for addressing prohibited conduct

1. Receipt of the complaint by UNEP or OIOS

The Office of Internal Oversight Services (OIOS), through its Investigations Division (OIOS/ID), retains the ultimate authority to review all complaints about unsatisfactory conduct. In view of this, UNEP is required to transfer all complaints received to OIOS/ID. OIOS/ID must then decide whether to review and investigate the complaint or refer it to UNEP for appropriate action – such as conducting a preliminary assessment, taking interim administrative and managerial actions, and requesting assistance from the Ombudsman’s office to conduct mediation or coaching.

There is no timeline for this phase of the process.

2. Preliminary assessment and investigation by UNEP

Upon receipt of a referral from OIOS/ID, UNEP conducts a preliminary assessment. The purpose of the preliminary assessment is to determine whether an investigation should be initiated. A preliminary assessment is not a formal investigation process and does not require investigators. It is primarily carried out by the Corporate Services Division/Legal Section or Corporate Services Division/Human Resources Section of UNEP, under the supervision of the UNEP Executive Director. Following the preliminary assessment, Corporate Services Division recommends actions to be taken, whether case closure, administrative or managerial actions, or the initiation of an investigation. The Executive Director makes the decision to initiate an investigation, based on a recommendation from the Corporate Services Division.

The timeline to conduct a preliminary assessment is three months.

3. Investigation

If a decision is made to investigate a report of possible unsatisfactory conduct, the Executive Director will appoint a fact-finding panel. The fact-finding panel comprises OIOS/ID-trained United Nations staff members, staff members with prior investigation experience, or retired staff members who have conducted workplace investigations and have received OIOS/ID training. Under ST/SGB/2019/8 - Addressing discrimination, harassment, including sexual harassment and abuse of authority, the Executive Director is required to appoint OIOS/ID-trained investigators to a fact-finding panel for complaints of harassment, abuse of authority, or discrimination. Other reports of unsatisfactory conduct listed in ST/AI/2017/1-Unsatisfactory conduct, investigation and the disciplinary process can be handled by trained investigators and/or current or retired United Nations staff members with prior investigation experience. Investigations conducted by fact-finding panels appointed by the Executive Director should comply with the Investigators' Toolkit.

The Department of Management Strategy, Policy and Compliance (DMSPC) maintains a roster of investigators who have been trained by OIOS/ID across the United Nations. Investigators on the roster can serve as investigators for any United Nations entity in need of one. The UNEP roster currently includes 13 trained investigators. Investigators are appointed only for the purpose of a fact-finding investigation, either by OIOS/ID or by the Executive Director.

Following an investigation, the fact-finding panel must prepare an investigation report to document the findings. Upon completion of the investigation, the fact-finding panel submits the report to the Executive Director. The Executive Director reviews the investigation report, following an investigation conducted by the fact-finding panel, and decides whether the reported conduct is found to be substantiated, may amount to misconduct and should, therefore, be referred to the Assistant Secretary-General for Human Resources (ASG/OHR) for further review and disciplinary process as necessary. If the conduct is not substantiated by facts, the matter will be closed. The Executive Director will also decide whether to take managerial or administrative action.

4. Timeline

It takes one month to set up the fact-finding panel after the decision to launch an investigation is reached.

There is no time limit for the investigation.

5. Disciplinary process

Upon referral of the investigation report by OIOS/ID or UNEP, the ASG/OHR reviews to decide whether to initiate a disciplinary process, should the facts indicate that the conduct of the alleged offender may amount to misconduct. There is no timeline for the review of the investigation report by the ASG/OHR.

If the ASG/OHR initiates a disciplinary process, the alleged offender is provided with formal allegations of misconduct, together with the investigation report and supporting documentation. The alleged offender is entitled to seek legal advice and provide comments. Further investigation by the ASG/OHR may be necessary. Upon receipt of formal allegations, the staff member has one month to respond.

Upon conclusion of the disciplinary process, the ASG/OHR may

(a) Close the case with no action,

(b) Refer the case to the Executive Director for managerial or administrative action and/or

(a) Decide that the facts are established to the requisite standard of proof,

(b) Impose disciplinary measures if the facts have been established and the behaviour amounts to misconduct,

(d) Decide on recovery of financial loss to the organisation in full or in part.

ASG/OHR informs the affected individual of the decision of the USG following the disciplinary process, with a copy to the Executive Director of UNEP.

Retaliation/Whistleblowing

1. Protection against retaliation/whistleblowing

According to ST/SGB/2017/2 REV. 1 - Protection against retaliation for reporting misconduct and for cooperating with duly authorized audits or investigations, retaliation is any direct or indirect detrimental action recommended, threatened or taken against an individual who officially reported misconduct or otherwise cooperated with duly authorised audits or investigations. If established, retaliation constitutes misconduct, which is subject to possible sanction.

Pursuant to the Secretary-General’s Bulletin (SGB), the United Nations Ethics Office reviews requests for protection. The bulletin encourages individuals to report fraud, corruption and other
potential misconduct without the fear of retaliation. Whistleblowers can file reports anonymously to OIOS.

The SGB enhances protection for those who report misconduct (any violation of the organisation’s regulations and rules by staff members) or wrongdoing (by any person that would be harmful to the interests, operations or governance of the United Nations), and for those who cooperate with duly authorised audits or investigations.

The ability to report misconduct or wrongdoing without fear of retaliation is a critical element to building an organisational culture of integrity, transparency and accountability.

A request for protection against retaliation should be submitted to the United Nations Ethics Office within six months of becoming aware of the retaliation.

2. Procedure

Requests for protection against retaliation or whistleblower reports should be made by anyone who has reported misconduct or participated in an investigation or audit and believes that he/she/they have been retaliated against. In such a case, the concerned individual(s) should contact the United Nations Ethics Office.

The United Nations Ethics Office is responsible for enforcing the anti-retaliation policy, which protects those who report wrongdoing.

The United Nations Ethics Office conducts “preliminary reviews” of retaliation complaints to ascertain whether a prima facie case of retaliation exists. Such a preliminary review is not considered an investigation. However, if the Ethics Office finds a prima facie case of retaliation, it then refers the matter to OIOS. OIOS conducts a full investigation, through setting up a fact-finding panel and gathering facts from different concerned persons. At the conclusion of the fact-finding investigation, OIOS transmits the findings to the United Nations Ethics Office for review and action.

The United Nations Ethics Office makes the final decision after reviewing the investigation report. Upon its recommendation, the UNEP may be requested to take administrative or managerial actions.

The process of addressing protection from retaliation/whistleblowing has been isolated from the concerned United Nations entity and will be handled by the UN Ethics Office to ensure impartiality in the review of such complaints.

The United Nations Ethics Office produces annual reports of its activities to the Secretary-General. Information on the activities of the United Nations Ethics Office, including the number of reports received for protection against retaliation, can be viewed online.

Fraud and corruption

UNEP has adopted a zero-tolerance approach to misconduct – including fraud and corruption involving its staff members, other United Nations personnel or third parties in relation to their work with UNEP. “Zero tolerance” means that UNEP will pursue all allegations of fraudulent acts involving any individual or entity covered by UN regulations, rules, administrative issuances, policies and procedures. The appropriate administrative/disciplinary measures or contractual remedies will be applied if fraudulent acts are substantiated in accordance with UN procedures concerning prohibited conduct.

Furthermore, UNEP may, where deemed appropriate, recover loss suffered by the organisation or refer matters involving credible allegations of criminal fraudulent acts to national authorities.

The United Nations has established a dedicated framework on fraud and corruption in ST/IC/2016/25 - Anti-Fraud and Anti-Corruption Framework of the United Nations Secretariat (the “Framework”). The Framework promotes a culture of integrity and honesty within the organisation by providing information to staff members on how to prevent, detect, deter, respond to and report on fraud and corruption.

UNEP has translated the Framework into the Anti-Fraud and Anti-Corruption Guidelines (UNEP AFAC Guidelines), which aims to strengthen the organisation’s prevention of and response to incidents of fraud and corruption by providing:

Concrete and practical advice to UNEP staff members in identifying potential risk areas;
A clear and user-friendly guide and reference for both external and internal audiences for awareness of controls put in place by UNEP, which are aimed at monitoring fraud and corruption; and
A consolidated procedure for sanctioning fraud and corruption.

On 9 December 2022, United Nations Under-Secretary-General Ms Catherine Pollard launched the Secretariat’s “Fraud and Corruption Awareness Handbook.” This helps staff understand how fraud and corruption can manifest in the various processes and functions of the Secretariat. It includes case studies reflecting some of the most common types of fraud and corruption experienced in the organisation, as well as red flags and indicators that may point to the possible presence of fraud and corruption. In addition, it contains references to mechanisms and channels for reporting fraud and corruption, as well as highlights of the process of investigations and imposition of sanctions. The Handbook is available in English and French.

How to report fraud and corruption

Reporting fraud and corruption follows the same procedure as reporting other prohibited conduct.

Confidentiality of the process

The process for dealing with prohibited conduct is confidential in order to protect the integrity of the process and the rights of those involved. To the greatest extent possible, the identities of complainants and witnesses are kept confidential and only disclosed to those who have a legitimate reason to know about the process.

UNEP Annual Reports on Conduct and Discipline and Fraud and Corruption

Conduct and Discipline: 1 January - 31 December 2023

Fraud and Corruption: 1 January - 31 December 2023

Conduct and Discipline: 1 October 2021 to 31 December 2022

Fraud and Corruption: 1 January to 31 December 2022

Conduct and Discipline: 1 August 2020 to 30 September 2021

Fraud and Corruption: 1 January 2020 to 31 December 2021