ANTI-FRAUD POLICY

Giridham Art and Culture Foundation

Last Updated: 09/02/2026

Giridham Art and Culture Foundation (“Foundation”, “we”, “our”, or “us”) is committed to maintaining the highest standards of integrity, transparency, and accountability in all financial and operational activities.

This Anti-Fraud Policy establishes procedures to prevent, detect, report, and respond to fraud, corruption, misappropriation, and financial misconduct.

1. Policy Statement

The Foundation adopts a zero-tolerance approach toward fraud and financial irregularities.

Any act of fraud, attempted fraud, or financial misconduct shall result in disciplinary and/or legal action.

2. Scope of Policy

This policy applies to:

  • Trustees & Governing Board Members

  • Employees & Program Staff

  • Volunteers & Interns

  • Consultants & Advisors

  • Vendors & Suppliers

  • Partner Organizations

  • Donors & Fundraisers (where applicable)

It covers all activities including:

  • Donations & grants

  • Membership fees

  • Foreign contributions (FCRA funds)

  • Resource contributions

  • Procurement & vendor payments

  • Event collections

  • Online payment gateways

3. Definition of Fraud

Fraud includes any intentional act to secure unlawful gain or cause loss to the Foundation.

Examples include:

  • Misappropriation of funds

  • Forgery or falsification of documents

  • Fake donation receipts

  • Unauthorized bank withdrawals

  • Inflated invoices or kickbacks

  • Identity theft or impersonation

  • Diversion of foreign funds

  • Misuse of NGO assets

  • Cyber fraud / payment gateway misuse

4. Financial Controls & Preventive Measures

The Foundation implements the following safeguards:

Banking Controls

  • Dual signatory system (where applicable)

  • Authorized payment approvals

  • Bank reconciliation reviews

Cash Handling

  • Limited cash transactions

  • Mandatory receipt issuance

  • Daily cash register maintenance

Donation Controls

  • Unique receipt numbers

  • PAN capture for large donations

  • Payment proof verification

Procurement Controls

  • Vendor verification

  • Comparative quotations

  • Purchase approvals

5. Digital & Payment Security

To prevent cyber fraud:

  • Secure payment gateways

  • OTP / authentication systems

  • Restricted admin access

  • Regular password updates

  • Monitoring of online transactions

6. Responsibilities Management / Trustees

  • Establish anti-fraud systems

  • Review financial reports

  • Approve audits

Finance Team

  • Maintain accurate accounts

  • Verify transactions

  • Flag irregularities

Staff & Volunteers

  • Follow financial procedures

  • Report suspicious activities

7. Fraud Risk Areas Identified

High-risk areas include:

  • Donation collections

  • Membership processing

  • Foreign funds utilization

  • Procurement & vendor payments

  • Event fundraising

  • Cash handling

  • Asset purchases

8. Reporting Fraud (Whistleblower Mechanism)

Any person suspecting fraud must report immediately.

Reports may include:

  • Financial irregularities

  • Forged documents

  • Fund diversion

  • Fake beneficiaries

  • Misuse of NGO name

Reporting Channels

Complaints may be submitted to:

  • Trustee / Board Member

  • Finance Head

  • Compliance Officer

Anonymous complaints may also be accepted if supported by evidence.

9. Investigation Procedure

Upon receiving a complaint:

  1. Preliminary review is conducted

  2. Financial records examined

  3. Statements recorded

  4. External audit engaged (if needed)

  5. Legal consultation obtained

Confidentiality shall be maintained throughout.

10. Disciplinary Action

If fraud is established, the Foundation may take:

  • Suspension

  • Termination of employment/association

  • Recovery of losses

  • Blacklisting of vendors

  • Police complaint / FIR

  • Civil or criminal legal proceedings

11. Protection of Whistleblowers

The Foundation ensures:

  • Protection from retaliation

  • Confidential handling of identity

  • Fair investigation process

False/malicious complaints, however, may invite disciplinary action.

12. Record Keeping & Audit

The Foundation maintains:

  • Donation registers

  • Bank statements

  • Utilization reports

  • Asset registers

  • Procurement records

Periodic internal and statutory audits are conducted.

13. Fraud Involving Foreign Contributions (FCRA)

Any fraud involving foreign funds shall be treated with heightened severity and reported to:

  • Ministry of Home Affairs (FCRA Wing)

  • Statutory auditors

  • Banking authorities

14. Policy Violations

Non-compliance with this policy shall be treated as misconduct even if fraud is not completed but attempted.

15. Policy Review & Amendments

This Anti-Fraud Policy shall be reviewed periodically and updated as per:

  • Legal changes

  • Audit findings

  • Operational risks

16. Contact for Fraud Reporting

Giridham Art and Culture Foundation

📍 Office Address:
Unit No. 259,
New Ashriwaad Industrial Estate No. 5,
Ram Mandir Cross Lane,
Goregaon (West), Mumbai – 400104

📞 +91 9969456938
📞 +91 8904011789
📞 +91 9591666047

📧 Email: giridhamacf@gmail.com