WOMEN FOR AFGHAN WOME

FINANCIAL MANAGEMENT MANAUL

This is to confirm that this manual has been

reviewed and confirmed by the board of directors
of Women for Afghan Women.

Sunita Viswanath

Chair of the Board

Women for Afghan Women

sunita@womenforafghanwomen.org
(917) 518-2441

Version: May 2016

Table of Contents:

1 - OVERVIEW 3

2 - IMPLEMENTATION 3

3 - PURPOSE 4

4 - BASIC PRINCIPLES 4

5 - CHART OF ACCOUNTS 5

6 - CASH MANAGEMENT 5

7 - PAYMENTS 8

8 - AUDIT 9

9 - PROCUREMENT 10

10 - ASSET MANAGEMENT 11

11 - REMUNERATION 14

12 - MATRIX OF AUTHORITY 15

13 - TRAVEL 16

14 - ANTI FRUAD POLICY 18

1 - OVERVIEW

This manual sets forth Women for Afghan Women Afghanistan related financial
management policies and procedures.

Women for Afghan Women is a United States based women rights, Not-for-Profit,
organization with major program activities in Afghanistan’s several provinces; it
strictly follows the United States Government’s financial management rules and
regulations as described in OMB (Office of Management and Budget) Circular A-122,
OMB Circular A-
133, as explained in OMB Uniform Guidance: Cost Principles, Audit, and
Administrative
Requirements for federal awards. WAW prepares and presents its financial
statements in accordance to Statement of Financial Accounting Standard 117 and
records contributions in accordance to Statement of Financial Accounting Standard
116.

Moreover, this manual also accommodates general provisions as they may comply
with WAW’s other donors. Unless restrictions are imposed by the United States
Government’s financial management compliance requirements, the manual’s
procedures can be flexible as far as reporting of financial activities.

2 - IMPLEMENTATION

The Executive Director assisted by the Financial Controller are ultimately

responsible for updating, implementing and enforcing this manual.

Afghanistan Country Director, as the guardian of financial assets (current and non-
current), ensures, through implementing the internal control mechanisms, that all
financial transactions are carried out in accordance to the policies and procedures
set in this manual as well as those communicated from the Executive Director and
Financial Controller.

By signing the monthly, quarterly and annual financial statements and projects
reports, she certifies that:

- Amounts of each financial statement account is accurate and supported by

approved, verifiable and legitimate documentation;
- Expenses reported are allowable, allocable to approved projects budgets and all
prices stated are the most reasonable price that could be obtained;

Financial Controller should be contacted for clarification on any matters, whether

included in this manual or not.
3. PURPOSE

The purpose of this financial manual is to guide the organization’s personnel

dealing with financial resources. The guidance extends to areas such as payroll,
travel, procurement of goods and services, cash management, asset
management, financial reporting, compliance, fraud prevention and reporting,
etc.

The manual is subject to amendments at no specific times. The organization’s

management may decide to introduce new procedures or policies when
deemed beneficial to the organization’s financial health – in line with
accounting principles generally accepted in the United States (GAAP),
Generally Accepted Government Auditing Standards, and any financial
management rules and regulations of the Government of Afghanistan.

4 - BASIC PRINCIPLES

WAW maintains its records of revenues and expenses on accrual basis, and prepares
its financial statements in accordance to Generally Accepted Accounting Principles’
Standard 117.

Because WAW’s sources of income are donations, grants and contributions, SFAS
116’s guidelines are used when dealing with contributions, donations and grants.

These standards dictate how we record and deal with contributions, donations and
grants and how we report and present them at end of fiscal or calendar years.
WAW’s fiscal year starts on March 1 and ends on end of February – the following
year.

WAW is also registered at Ministry of Economy of the Government of

Afghanistan, thus it is obliged to report and account for activities to various
Afghan government offices/entities. The formats of reports to these entities are
determined by the official guidelines issued by the requesting Afghanistan
government agency.

WAW’s financial management policies demand that fair and transparent financial
management practices are followed. WAW has zero tolerance for fraud and
intentional negligence towards organization’s assets (cash, expendable and non-
expendable).
5 - CHART OF ACCOUNTS

Women for Afghan Women keep two company files: New York QuickBooks files and
Kabul QuickBooks files. The chart of accounts of each file is different for the
purposes of properly recording, classifying, summarizing and presenting the financial
transactions of WAW.

Both books (financial statements and related reports) are submitted to Financial
Controller for consolidation purposes at end of each fiscal year or any other period
as deemed necessary.

The chart of accounts is subject to periodic changes; changes will be noted

and approved by the Executive Director.1

6 - CASH MANAGEMENT

6.1 Summary

Cash refers to cash in the bank and in petty cash; also, cash equivalents are
considered as cash and they include advances to personnel.
Pre-paid expenses (payments to landlords or other vendors) are treated as
receivables. At WAW, cash management in general refers to the business of
receiving donor funding, maintaining cash in the bank and in the office safe,
paying out cash advances or paying directly to vendors for the procurement of
goods and services.

6.2 Currencies

WAW’s donors may contribute to WAW’s projects/operations in any currency that is

of value.

6.3 Bank Accounts

All bank accounts have dual signatories. For control purposes, the bank alert system
is requested so any withdrawals of large sums of cash is reported immediately to the
designated authorized personnel. In Afghanistan, the person would be the Country
Director. The Executive Director is informed on a regular basis of all large deposits
and payments.
Only the financial controller can authorize closure or opening of a new bank account in
Afghanistan. The authorization has to be in writing.

1 Annex 1: latest Afghanistan Chart of Accounts

.

6.4 Bank Reconciliation

The finance department in Kabul must prepare bank reconciliation, for all bank
accounts, at the end of each month and submit them to the Country Director for
review and approval. Copies of the approved bank reconciliation are, then,
submitted to the financial controller.

6.5 Advances

Cash advances are only paid for the purposes of enabling WAW personnel to
procure goods and services for the operation of cost centers. No cash advance is
granted for personal expenditure purposes.

A new cash advance will be approved after prior cash advance (the amount) has
been cleared and all applicable receipts (documents) are submitted to the finance
department.

6.5.1 Advances to Cost-Centers

All funds must be at designated bank accounts at all time, except for a small amount
of petty cash that could be held at a secure place, a locked safe, on location. Access
to the safe is restricted to finance personnel only. The amount of cash – on any
location – should not exceed Afghani 25,000 at any given time. Payment to vendors
and suppliers should be made through bank transfers or check. Request for payment
by cash could only be approved by the country director – on rare occasions. A
justification has to be filed along with the payment documents as to why the
payment was requested and approved by cash.

6.6 Cash receipts

All donor funds (grants, individual donations, contributions) are to be transferred to

WAW designated bank accounts. The financial controller or his/her designee will
designate the bank accounts

6.7 Project specific funds

Funds of one project cannot be transferred to any other projects.

6.8 Currency conversation

The official currency of Afghanistan is Afghani – AFN - thus all cost-centers are
encouraged, to the extent possible and when it does not disrupt business
.
operations, to use Afghani when paying for goods and services in Afghanistan. The
exchange (conversion) process of US Dollars, Euro or any other currency of the
donor agencies into Afghani (currency) is of paramount importance, and has to be
carried out as following:

- Conversion of more than $2,000/or equivalent into Afghani has to be done

through bank account conversion. This involves transferring foreign currency
funds from the project’s one bank account to designated Afghani currency bank
account of the same project;

- Table of conversion must be kept at financial management office in Kabul,

with monthly report of conversions submitted to New York HQ;

- All conversions should be initiated after officially getting approved by the

country director or her designee;

- Conversions outside the banking system have to be based on the prevailing

exchange rate. Proper receipt of conversion should be retained and noted in the
system (conversion control account);

- Finance department should always keep a monthly Da Afghanistan Bank exchange

rate report on file. Any currency conversions should not deviate from the official DAB
exchange rates. If the commercial bank’s exchange rate is any different, finance
manager should make note and report it.2

2http://dab.gov.af/en/DAB/currency
7 - PAYMENTS

7.1 Payment Method Table

Payment range Payment method

Payment through cash is allowed,
$1-
but highly discouraged.
$200
Payment by check is mandatory, except
in circumstances that would disrupt the
normal activities of WAW and paying by
$201 - check limits WAW’s logistic personnel’
$500 ability to carry out procurement of
goods or services

Bank Transfer is the preferred method

for
$500 -
this range. In rare circumstances,
$5,000
payment by check could be authorized
by the Country Director.
$5,000 Only by Bank Transfer
+
Head of Operation is ultimately responsible for authorizing payments. Thus, all
payments must be verified by the Head of Operations and HoO can only authorize
any payments that may, in exceptional/rare cases, not comply with the above
table.

7.2 Checks: all check books are kept in safe, and in secure locations. Checkbooks
are maintained by the finance department’s designated personnel. Check payments
are one of the preferred methods of payment for procurement of goods and
services.

Authorized personnel must not sign blank checks under any circumstances. All
voided checks must be recorded and kept on file.

7.3 Bank transfers: Bank transfers are the preferred method for any payment
range and for any type of procurement of goods or services. When possible, WAW
personnel should always choose bank transfer over any other methods.

Minimum support documentation, in order to initiate a bank transfer, includes:

- Approved procurement request form;
- Purchase order;
- Goods received note;
- Payment authorization form, signed by the Head of Operations or Country Director.
For payroll, all staff names should correspond to the Master Payroll and the HRMIS
records. HR Department must sign off on the payroll sheet to verify that all
employees listed have valid contracts of employment and that each listed
employee have signed a time sheet/ attendance form.

7.4 Petty cash payments: petty cash at WAW offices are always to be kept at
minimum levels. The allowable petty cash amount, at any one time in a WAW
office, is $500.

8 - AUDIT

Women for Afghan women, as a US based organization, is required by law to file

annual audit reports carried in accordance to OMB Circular A-133. As such, all
financial records and financial statements are prepared in accordance to the
Statement of Financial Standards 117 (presentation of financial statements for Not-
for-profits).

The board of directors’ audit committee will put out solicitation for annual audits
to potential audit firms.

It is the responsibility of the board of directors to oversee the work of the auditor
and to review the draft audit report before the report is released.

There are 3 different types of audits that WAW’s financial books are subject to:

1. Annual audit in accordance to OMB Circular A-133: without exception

should take place at end of each fiscal year;

2. Project specific audits: depending on the terms of the agreement, these

audits take place after the end of the project;

3. Government/donor sanctioned special audits: in rare circumstances, donor

(government or institution) may contract an external auditor to carry out
audit of one or a series of a project implemented by WAW.
9 - PROCUREMENT

The procurement of goods and services for business operations of WAW in

Afghanistan is the responsibility of the Logistics Department.

Procedure for procurement is as following:

- Requests for goods and services are prepared by the requesting cost-
center’s specific department;
- The field logistics assistant carries an initial check of the availability of the
item (in cases of requests for goods) and verifies that the item is not
available in the stock;
- Field logistics assistant requests field finance assistant to verify availability of
funds for the procurement of requested goods or services;
- The provincial manager approves the request (for any requests up to
$200) and procurement is carried out.

The above process is applicable to all field requests, except the following cases:

- Goods and services requested cost more than $200;

- Goods and services are not available in the provinces, in which case
requests are passed on the Kabul HQ logistic team to carry out the
procurement;

In following cases (which is not an all-inclusive list) Kabul HQ logistic team

must involve the Executive Director and the Controller:

- Procurement of vehicles;
- Procurement of services – of recurring nature – with a cost of more than
$1,000 per month;
- Procurement of assets other than vehicles that cost more than $1,000. For all
fixed asset procurement costing $5,000 or more, WAW must seek donor’s
approval. Approval for such procurement will be requested by the Executive
Director through an official request;
9.1 Real Estate Property Rental:

WAW rents its premises in all locations in Afghanistan. The process of renting
premises is similar to procurement of goods and services, except the Executive
Director approves all lease agreements.

Documents that must be attached to a request for approval are:

a. Security assessment of the premises;

b. Three price quotations and comparative table justifying why we are selecting
the house that we are selecting;

c. If 3 quotations could not be obtained, a memo justification signed by Security,

Head of Operations and Country Director;

d. All amounts on leases are stated as gross figure.

9.2 System Award Management (SAM): A large portion of WAW projects are
either directly or indirectly funded by the US Federal Awarding agencies including
State Department and USAID. WAW follows the policy to background check all
vendors with whom WAW enters into a transaction, the value of which, at any
given moment, exceeds $2,000. The background-check procedure includes
entering the vendor’s name in www.SAM.gov designated field.

WAW’s offices are prohibited to enter into any financial relationship with vendors
as well as employees who are designated eligible for business.

10 - ASSET MANAGEMENT

10.1 What is an Asset (definition):

WAW distinguishes between a fixed asset item and an expandable (inventory) item.
All fixed items have a useful life of more than one year, and have a market value of
$100 at the time of procurement.

10.2 Asset Management Information System:

All assets at the possession of WAW (whether property of the donor or WAW’s),
are recorded in the Main ASSET MANAGEMENT INFORMATION SYSTEM that is
maintained by the Logistics Department in WAW Kabul Main Office.
A separate list is also maintained in each cost-center, by the logistics assistant
and the cost-center/provincial management team. The two lists of items referring
to a cost- center must reconcile at all time.

All asset items should be tagged – with a unique identification number.

Asset items (including vehicles) should be recorded in such a manner that reports
by donor, project and locations are always producible and available;

10.3 Procurement of Asset:

Because of the value of asset items, procurement of any asset item up to a cost of
$200 requires 3 quotations from different sources. The matrix of authorization in
this manual clearly explains who could sign off on procurement authorization for an
asset item.
To summarize: Provincial Manager can sign off on assets costing up to $200.
Head of Operations can sign off on procurement authorization for an asset costing up
to $500.
Items costing more than $5,000 require donor’s approval; this approval is obtained
by the Executive Director. Financial Controller has to be informed of any such
procurement.

10.4 Transfer, Depreciation, Disposal and Sale:

Any fixed asset item procured with donor funding is the property of the donor until
title is transferred – officially – to WAW. Therefore, any sale, disposal or gift of
assets should be pre-approved by the authorized representative of the donor
agency. WAW Reports assets specifications to the Ministry of Economy on regular
basis and all these assets are registered in MOE and in case of disposal and sale of
asset we need to inform MOE and go through official process to remove it back from
MOE List.

10.4.1 Transfer: Transfer of assets from one location to another should be

avoided if possible. When such a request is made, the country director
and head of operations should ensure that any such transfers are
temporary and all documentation is on file to ensure return of the asset to
its original location.
 10.4.2 Depreciation: WAW uses straight line depreciation, and observes the
useful life table for recording depreciation of assets.

10.4.3 Disposal: Disposal of an item can be approved by the Executive

Director, for assets costing less than $2,500 and by donor agency for
items costing more than $2,500.

All such requests should be made by the country director’s verification

and the assets to-be-disposed should be listed and with pictures taken.
An asset can only be disposed of when it meets these criteria: it is of no
use by WAW; there is no active buying market for it; the cost of readying
it for sale is higher than its net realizable value, and the donor agency has
not found a party who has a use for the asset.

Proper disposal plan has to be prepared, which would also include filing
of the documentation and proper recording of the disposal on the Asset
Management Information System.

10.4.4 From time to time, WAW’s management may authorize sale of assets.
The criteria for the resell are: WAW cannot use the asset because of its
wear and tear, or because it has lost its purpose; WAW could use the
proceedings from sale to fund procurement of a similar newer item, or to
procure another asset for the project. All resell requests has to be
properly documented and submitted to the financial controller who would
review and pass it on to the Executive Director. The final approval for the
resell is issued by the donor, if the title of the asset has not been
transferred to WAW, already.

Table: useful life of assets

Items Useful life
Computers, Printers, Copiers, TV sets, 5 years
and other
electronic equipment with close
resemblance
Furniture andto items mentioned
Fixture 5 years
Vehicles 30 years from the manufacturing date. If
a vehicle
is purchased used, the difference
between the purchase date and
manufacturing date should be deducted
from 30 to arrive at the remaining
useful life
11 - REMUNERATION

General: WAW may issue different types of contracts for employment or service.
These include part-time employment contract, consultancy contract or full time
staff contract. Contract duration may vary depending on factors including donor
funding and the required deliverability of a specific service.

All salaries are stated as gross.

11.1 Time Keeping

Unless specified otherwise, all WAW staff members (including consultants) are
required to submit a time sheet to the Human Resources office or the designated
person on site.

Time sheets must reflect hours worked and specific area/project worked on;

11.2 Payroll Processing

Payroll is processed once a month, after the end of each calendar month. The exact
day of the payment may not be fixed.

Staff members must submit their individual bank information to the HR office at
the start of their employment. All staff salaries are paid through bank transfer to
the individual employee’s designated bank account; in exceptional cases, the
Head of Operations can authorize payment of salary by check. A note has to be
made on the authorization form.

11.3 Taxes

WAW calculates applicable and levied taxes on salary and benefits of employees,
withholds the tax portion of the salary and pays the total withheld amount on
behalf of employee through bank transfer to the account of Ministry of Finance as
soon as possible. Annual tax return forms are also prepared with one copy kept on
file and one copy given to individual employee for her/his records;

WAW deduct the taxes on all contracts with vendors and lease agreements with
landlords and pay the withhold amount to the government on behalf of the
vendors
11.4 Bonuses

WAW management recognizes the level of effort, the difficult circumstances and
hardship under which staff perform their duties. From time to time, WAW’s board of
directors or the Executive Director may approve payment of bonus to one or group
of staff, as performance based bonus; WAW also recognizes religious holidays or
national Afghanistan holidays. Depending on the availability of funds, WAW
management may also approve EID or NAW RUZ payments to its staff; however,
EID and NAW RUZ payments are not guaranteed.

11.5 Overtime

Overtime is only paid in rare cases to a staff member who has performed duties
beyond and above the required number of hours. Overtime has to be pre-approved
by the manager.

11.6 Fringe Benefits

As of 2015 calendar year, WAW provides medical allowance of $25 to all WAW
Afghan staff on monthly basis. Further, WAW also pays for transportation costs of
some employees considering the specific employee’s working hours, gross salary
scale and etc.

Other fringe benefits may get included in the employment package offered to staff
in the future. Introduction of any additional fringe benefit items are dependent on
the availability of funds and conclusion by the management and the board of
directors that the additional benefits would have a positive impact on the overall
performance of the organization.

12 – EXPENDITURE AUTHORITY THRESHOLDS:

Purpose: Establish responsibilities and procurement authority approval levels for

personnel involved in procurement at the country using A. Project Funds and B.
Non Project (General and Administrative) Funds.
A. project Funds

Goods/Services
The matrix of authority to approve procurement of goods and services are as
following:

Approval Authority Counter-signing Donor

Range authority approval
requir
$1- $200 Provincial Manager No edNo
$200 - $500 Head of Operations No No

$500 - Country Director No No

$1,000
>$1,000 Executive Director No No

B. project Funds

B. Non Project- (WAW General and Administrative) Authorized

Funds Finance Verification Primary Approval Limits
International Controller Executive Director >$
1

Employment
Approval Authority Counter-signing Donor
Range authority approval
$1- $500 Country Director Executive Director Yes, requir
through
ed
approved
$500 - $4,000 Executive Director budget
Yes, through
approved budget
$4,000 + Executive Director Board of Directors Yes, through
approved budget

13 - TRAVEL

13.1 International travel

Staff members who travel internationally on WAW’s official business are entitled
to coverage of their travel costs. There is no distinction of travel cost coverage for
junior level or senior level personnel. The travel policy is uniform and applies to
all WAW staff members, board members, consultants and advisors.
Travel reports must be submitted to the financial department within 30 days of
the return from the trip. Without boarding passes – for air travel – a travel
expense claim cannot be processed. Travelers must retain their boarding passes
and submit them to the financial department when clearing their advance or
claiming reimbursement.

The travel cost categories include:

- TRANSPORTATION: Air ticket/taxi/ship and any other means of

transportation cost that would take the staff member from her/his base
location to the official destination and return;

WAW only provides economy class air-tickets to staff members. Should a

staff member choose to upgrade to a upper-class seating, the excess cost
would need to be paid for by the traveler;

- Per Diem: Meals & Incidental Costs: this covers the cost of 3 meals a day, and
incidental expenses that are necessary and that the staff member would have
carried them at his base location (e.g: laundry, communication, etc). WAW’s
policy is to pay for the actual cost of meals and incidental expenses. Travelers
must submit original receipts of payments for meals and any incidental
expenses;

In lieu of receipts, traveler must certify in writing that claimed expenses

“incurred while traveling for the purposes of advancing WAW’s mission and
all calculations are accurate to the best of my knowledge.”

- Accommodation: this only includes hotel accommodation for overnight stays

at final travel destination or in transit;

- Approval: all international travels must be pre-approved by the Executive

Director. Requests must be submitted to Executive Director in writing with
details of the travel. Details should include location(s), purpose, dates, and
any notes;

- Travel Advance: advance funds can be provided to traveler on request.

Traveler must provide an estimated cost for each category of cost stated
above. Cash advance request must be submitted to Executive Director for
approval along with the travel request;
 - Reimbursement: any expenditure that were incurred for the purposes of
official travel, and for which a cash advance had not be requested/ or
provided, will be reimbursed. Travelers are expected to submit a
reimbursement claim, no later than 30 days on return. All original receipts
must be attached to the form; should any receipts be missing, a note in lieu
of receipt should be submitted that is signed by the traveler to verify that the
cost actually happened and was necessary for the purposes of the travel.

- Travel Insurance: WAW does not have an international insurance coverage

for international travel. Given the financial constraints, this cannot be
implemented at current; however, in future this may be considered.

13.2 In-Country Travel

In country travel is referred to travel, on official WAW business, from the base
location/province to another. Often times it may involve overnight stay or it may
not.

Following procedure is applicable for all in-country travels:

- Travel authorization must be approved by the immediate supervisor, who

would verify the need for travel;
- The security manager’s advice should always be sought and obtained prior
to departure;
- Country Director should be informed, through email, of the detail for the
travel;
- Any requests for travel advance should be approved and all aforementioned
per diem, travel advance and insurance clauses apply to in-country travel.

14 - ANTI FRUAD POLICY

WAW has a zero-tolerance policy towards fraud. As such, WAW management
strives to introduce policies and procedures as well as other fraud preventative
measures to ensure the business of protecting Afghan women is conducted at the
highest standard possible.

The aim of this policy is to guide WAW staff to conduct their activities in such a
manner that is not prone to fraudulent activities; these activities could be
intentional or unintentional acts that could be construed as fraud by an independent
audit.

The Anti-fraud policy of WAW applies uniformly to all WAW offices, projects and
any other activities. Fraud includes but is not limited to the following:
 - Theft of funds, asset items, inventory items;
- Inappropriate personal use of WAW assets;
- Falsification of costs or expenses;
- Destruction of critical data – intentionally;
- Accepting extravagant gifts in the form of cash or other favors from vendors/
contractors or other third parties in return for awarding contracts to them;
- Blackmailing;
- Paying of excessive prices or fees to third parties for personal gains;
- Falsifying recruitment documents of qualified candidates in order to hire
friends and families – by putting them in an advantageous position than the
qualified candidates;
- Intentional misrepresentation, or delay in provision of, critical financial data;
- Falsifying timesheets.

Responsibilities:

a) Managers: those with staff management responsibility must make

themselves familiar with the above list in order to identify fraud when it
occurs;

b) Staff members – in general: all staff members should be familiar with the
above list and ensure that they are mindful of their actions at all time. Staff
members also have the responsibility to report any other members of staff
when one is caught in a fraudulent act. WAW’s whistleblower policy will
ensure that staff will not be subject to any retributory reaction from the
management, the accused or any other parties;

c) Staff with money/asset management responsibilities: staff who manage cash,

procure goods and services, record and safeguard organizational assets are at
the forefront of the effort to keep WAW a transparent, accountable and fraud-
free organization.
These staff members must go through the Anti-Fraud briefing at least once
a year. Moreover, these staff members are expected to keep themselves
up to date with any incidents of fraud that happened elsewhere and could
potentially be a risk for WAW too.

Reporting: staff are required to report cases of fraud to their immediate

manager/reporting officer. If employee suspects that her/his immediate
supervisor may be a party in the fraudulent act, she/he should reach out to the
manager one level higher than hers.

Staff should always ensure that they are not mistaken the act, and
determine that it is a fraudulent activity that they are reporting.

Employees should not contact the suspected individual. Do not discuss the issue
with anyone else except your manager or the manager one level up.

Field management, in case the act took place in one of the field offices, should
immediately contact WAW Country Director and report the incident with full
details. All details should be documented with witness/es accounts of what actually
happened, date, time, place and nature of the fraudulent act.

Should you feel like your report will not be taken seriously, email the
incident to office@womenforafghanwomen.org or call +1 718 591 2434

Investigation:

Timeline of the reporting of any fraudulent activity is: first line of manager should
report the incident to provincial manager within 24 hours. Provincial manager
should report the incident with full detail to Country Director within 48 hours.

Country Director should form the fraud investigative team (consisting of a member
of finance, program and human resources teams) to review the evidence, facts and
any other clues that may prove or disprove the illegal act. A member of the
department accused of fraud cannot be a member of the investigative team.

Investigative team has 72 hours to review the evidence and submit their report,
in writing, to the country director with a copy to the executive director of the
organization.

The investigative team should consist of individuals with full knowledge of the Anti-
Fraud policy, should have gone through at least one Anti-Fraud briefing, be a staff
member of WAW for more than one year, and not be related to the accused. Also,
personnel with a previous written warning letter on file cannot be a member of the
investigative team.

Recommendation of the fraud investigative team: The team should

propose a disciplinary action based on the guidelines of the staff handbook’s
section on disciplinary procedures.

Country director has the discretion to reduce the punishment of minor cases
should she determine that staff member found guilty of the act did that with
some degree of innocent ignorance.

The ultimate disciplinary action will be introduction of the person found guilty of
fraudulent activity to the law enforcement agencies.

In severe cases, especially involving huge sums of money or valuable assets,

termination without any pay is imminent. The investigative team’s report will also
be filed in the accused’s personnel file permanently barring her/him from ever
getting hired by Women for Afghan Women and its sub-contractors.

Recovery of losses: the replacement cost of the any asset (cash or fixed asset)
will be sought of the salary and benefits of the staff member. Should the value of
the loss exceed the benefits and salary of the accused, he/she is responsible for
compensating WAW either in full immediately, or in installments. Accused also
should present a guarantor to guarantee full payment of the compensation will be
made.

Annex 1: WAW Afghanistan Chart of Accounts