Contacts

13901 State road, North Royalton, Ohio 44133
Unit 33021

info@wwh.us.org

+1 (818) 397-2393

Introduction

World With Hope is committed to complying with relevant laws and any contractual obligations applicable to us relating to counter-terrorism. This policy sets out our commitment and provides a guide for our personnel on what to do if there is actual or suspected non-compliance.

Scope of the Policy

  1. All our personnel (being our Committee members, employees, volunteers and consultants)
  2. All our partner organizations and sub-contractors, and their personnel, involved in implementing our projects or programs or involved in activities resourced by us
  3. All funds and in-kind resources for our programs, projects or activities in the United States and overseas.

Policy Statement

  1. We will exercise reasonable efforts to prevent our assets and resources (including funds) from becoming support, directly or indirectly, for any of the following entities and their activities:
        i. A terrorist (being a person, group or organization who is listed in a Relevant List as defined below)
        ii. Any organization or individual on whom the United States has imposed sanctions or who is listed in a Relevant List. 
  2. We will take steps to ensure that we do not associate in any way with any person who is an individual or organization of the type described in paragraph (1) above.
  3. We will also take steps to ensure that obligations relating to counter-terrorism are also assumed by our partner organizations and subcontractors where we work
    with them.

Policy in Practice

Our Personnel:
  1. We will screen prospective personnel in the relevant manner set out in the procedures below
  2. This policy will be embedded within our organizational culture and practices. We will create awareness amongst our personnel about terrorism risks and counter- terrorism measures by providing and explaining this policy to them.
Our partners and subcontractors :
  1. Awareness about terrorism risks and counter-terrorism measures will be a criteria when we assess the suitability of a prospective partner or sub-contractor.
  2. We will take the relevant steps set out in the procedures below in relation to our partners and subcontractors.
Procedures :
  1. Pre-appraisal: We will do the following as pre-appraisal of each prospective personnel before they are recruited and partner or sub-contractor before they are engaged in connection with the relevant programs, projects or activities with or for us.
        i. Confirm their identity, credentials and general good standing through interviews and reference checks with reputable referees. 
        ii. Undertake screening as follows:
            a. In the case of individuals, check their own name against the Relevant Lists
            b. In the case of organizations, check the names of their key persons, that is: those who are involved in their governance (for example, members of their board);
            those in senior management (for example, their executives), financial management and control at the organizational level (for example, their chief financial
            officer, financial controller or finance manager); and those responsible at the program, project or activity level (for example, project finance manager), against the
            Relevant Lists. We will not engage (or otherwise associate with) the individual or any organization who has a key person whose name is on a Relevant List. 
        iii. Provide them with this policy and seek confirmation from them that they understand and can commit to complying with this policy and relevant laws relating to
        counter-terrorism. 
  2. Re-appraisal:
        i. our personnel by undertaking screening as set out in paragraph 1(ii)(a) above every 5 years
        ii. the key persons of partners and subcontractors (in the manner set out in paragraph 1(ii)(b) above) where our partnership or relationship with them has a term of over a year with the following frequency
  3. Retention of appraisal records: We will retain records of all appraisals undertaken.
  4. Measures with partners and subcontractors:
        i. We will provide this policy to our partner organizations and sub-contractors and through our agreements with them, require them to apply this policy unless they have a commensurate or more comprehensive policy.
        ii. We will require our partner organizations and sub-contractors to require a similar commitment from any other organization or person they engage in connection with the relevant programs, projects or activities with or for us. 
        iii. We will work with our partner organizations and subcontractors to:
            a. identify terrorism risks in relevant programs, projects or activities they undertake with or for us and identify and take the appropriate measures to prevent and
            minimize such risks. Depending on the context and the nature of the program, project or activity, the appropriate measures may include some or all the steps set
            out in the procedures to this policy and where necessary, additional steps.
            b. ensure their personnel are aware of counter-terrorism measures and take steps to mitigate against any of our resources becoming support for terrorists and
            their activities or us becoming associated with them
        iv. We will monitor our partners’ compliance with this policy and the undertakings in our agreements with them from time to time. In particular, we will ensure that regular checks undertaken to verify whether the controls set in this Policy are complied with.
  5. Transfer of funds: Any transfer of funds must be done in compliance with our Transfer of Funds Policy.
  6. Incidents: In the event of any incident where there has been, or suspected to have been, non-compliance with this policy or our obligations under a relevant law or any contract relating to counter-terrorism:
        i. personnel must inform our Public Officer immediately
        ii. our Public Officer must ensure that appropriate actions must be taken to address the incident including the following as appropriate:
            a. immediate cessation or suspension of resources (including funding) being provided (for example, to the relevant program, project or activity)
            b. investigation of the incident
            c. notification of the incident and steps taken to relevant authorities and to the other parties under the terms of a relevant contract (if and as required) and our
            Committee.5 

Ownership, monitoring and Review of Policy

Our Committee owns this policy. This means that:
  1. Our Committee will be provided with regular reports (but in any event no less than two (2) reports in each calendar year) by our Vice President about compliance with this policy and where any compliance issue is identified, our Committee will ensure that the issue is addressed appropriately and promptly.
  2. If any exception or departure from this policy is proposed our Vice President must be informed and our Vice President will seek our Committee’s prior approval to the exception or departure. No action will be taken (or inaction allowed) until our Committee has made its decision on the proposed exception or departure.
  3. Our Committee is responsible for reviewing this policy regularly (minimum every two years).
  4. Any updates and revisions to this policy must be approved by our Committee.