Code of Conduct & Policies

St. Mary's Global Foundation for Education and Health (the "Foundation") is committed to the highest standards of professional conduct in all its operations. This Code of Conduct applies to all individuals acting on behalf of the Foundation, including board members, staff, consultants, volunteers, interns, and partner organisations (collectively "Personnel").

Adherence to these standards is not merely an obligation — it reflects the values that underpin everything we do: serving vulnerable communities in South Sudan with honesty, compassion, and respect.

1.1 Integrity & Honesty

All Personnel must act with honesty and transparency in all professional matters. This means:

• Providing truthful and accurate information in all communications, reports, and donor updates.
• Never misrepresenting the Foundation's work, finances, or impact to any stakeholder.
• Acknowledging and correcting errors promptly rather than concealing them.
• Maintaining full and accurate records of all activities conducted on behalf of the Foundation.

1.2 Respect & Dignity

All Personnel must treat every person — whether a beneficiary, colleague, partner, or donor — with dignity and respect, regardless of gender, age, nationality, ethnicity, religion, disability, sexual orientation, or any other characteristic.

• Discriminatory language, attitudes, or behaviours of any kind are strictly prohibited.
• Personnel must respect the cultural practices and customs of the communities in which the Foundation operates.
• Any form of harassment — verbal, physical, or psychological — is unacceptable and will result in disciplinary action.

1.3 Accountability

The Foundation operates as a steward of resources entrusted to it by donors, governments, and the communities it serves. All Personnel are accountable for:

• Using Foundation resources solely for their intended purposes.
• Complying with all applicable laws and regulations in South Sudan and any other jurisdiction in which the Foundation operates.
• Following all Foundation policies, procedures, and guidelines.
• Cooperating fully with any audit, investigation, or review conducted by the Foundation or its authorised representatives.

1.4 Conflict of Interest

Personnel must avoid situations in which personal interests conflict — or could appear to conflict — with the interests of the Foundation.

• Any potential conflict of interest must be disclosed immediately to a supervisor or the Foundation leadership.
• Personnel must not use their position within the Foundation for personal financial gain or to benefit family members or associates.
• Gifts, hospitality, or benefits that could reasonably be perceived as influencing a professional decision must be declined and reported.

1.5 Professional Behaviour

• Personnel must maintain a standard of conduct — both on and off duty when representing the Foundation — that upholds the reputation of the organisation.
• Public statements, social media activity, and media engagement on behalf of the Foundation must be accurate, respectful, and consistent with the Foundation's mission.
• Personnel must not engage in any political activity that could compromise the Foundation's independence or neutrality.

1.6 Use of Resources

• Foundation assets — including funds, equipment, vehicles, data, and intellectual property — must be used only for authorised purposes.
• Personnel must take all reasonable precautions to protect Foundation assets from loss, damage, waste, or misuse.
• Expenses must be accurately reported and supported by valid documentation.

1.7 Non-Discrimination

The Foundation is committed to equal opportunity in all its activities. Selection of beneficiaries, procurement of services, and employment decisions will be made without discrimination on the basis of race, colour, sex, religion, national origin, disability, or any other protected characteristic. Programming will prioritise the most vulnerable and marginalised populations consistent with the Foundation's mission.

2.1 Purpose & Scope

This Safeguarding Policy reflects the Foundation's firm commitment to the safety, dignity, and well-being of every child and vulnerable adult with whom it works. The policy applies to:

• All Foundation Personnel as defined in Section 1 above.
• All programmes and activities in which children or vulnerable adults participate, directly or indirectly.
• All partner organisations and contractors who act on behalf of the Foundation or who interact with beneficiaries.

The Foundation acknowledges that working in fragile contexts such as South Sudan — where pre-existing vulnerabilities are heightened by conflict, displacement, and poverty — places a heightened duty of care on all Personnel.

2.2 Definitions

• Child: Any person under the age of 18 years, in accordance with the UN Convention on the Rights of the Child.
• Vulnerable Adult: Any adult who, due to illness, disability, mental impairment, or social circumstance, may be at greater risk of harm or exploitation.
• Abuse: Any act or omission that causes harm to a child or vulnerable adult, including physical, emotional, sexual, and economic abuse, as well as neglect.
• Sexual Exploitation: Any actual or attempted exchange of money, employment, goods, or services for sexual access to a beneficiary, including by a person in a position of power over that beneficiary.
• Harassment: Unwanted conduct related to a protected characteristic, or unwanted conduct of a sexual nature, that has the effect of violating a person's dignity or creating an intimidating, hostile, degrading, or offensive environment.

2.3 Responsibilities

Foundation Leadership is responsible for ensuring this policy is implemented, that adequate resources are allocated to safeguarding activities, and that all reported concerns are investigated promptly and impartially.

All Personnel are responsible for:

• Understanding and complying with this Safeguarding Policy.
• Treating all children and vulnerable adults with respect and dignity at all times.
• Reporting any concern, allegation, or incident of abuse, exploitation, or harassment immediately through the reporting channels described in Section 4.
• Never placing themselves in a situation that could be perceived as abusive or exploitative.
• Maintaining appropriate professional boundaries with beneficiaries at all times.

Partners and Contractors are required to adopt equivalent safeguarding standards and cooperate fully with any investigation initiated by the Foundation.

2.4 Safeguarding Commitments

The Foundation commits to:

• Conducting risk-based safeguarding assessments before commencing any programme activity involving direct contact with children or vulnerable adults.
• Carrying out background checks and reference verification for all Personnel who will have direct access to children or vulnerable adults.
• Providing mandatory safeguarding training to all relevant Personnel before they are deployed in the field.
• Maintaining records of all safeguarding concerns, allegations, and investigations in a secure and confidential manner.
• Cooperating fully with law enforcement authorities and relevant government bodies in South Sudan in respect of any safeguarding incident.
• Reviewing this policy annually and updating it in line with evolving international standards, including UNICEF's Procedure for Addressing Misconduct, the UN Protocol on Allegations of Sexual Exploitation and Abuse, and applicable national legislation.

2.5 Prohibited Conduct

The following behaviours are strictly prohibited for all Personnel:

• Engaging in, facilitating, or condoning any form of sexual activity with a child under any circumstances.
• Engaging in sexual exploitation or sexual abuse of any beneficiary.
• Using language, images, or materials of a sexual nature in the presence of children or vulnerable adults.
• Physically punishing or humiliating a child or vulnerable adult.
• Photographing, filming, or sharing images of children or vulnerable adults without documented informed consent from a parent or guardian and without approval from Foundation leadership.
• Discriminating against any child or beneficiary in the delivery of services.
• Failing to report a known or suspected safeguarding concern.

St. Mary's Global Foundation is entrusted with resources contributed by individual donors, grant-making bodies, governments, and multilateral institutions for the express purpose of serving communities in South Sudan. The Foundation treats the prevention of fraud, corruption, and misuse of funds as a fundamental governance obligation.

3.1 Scope

This policy applies to all Personnel and to all financial transactions involving Foundation funds, assets, and resources, whether managed in Juba or elsewhere. It applies regardless of the amount involved — there is no de minimis threshold for fraud or corrupt conduct.

3.2 Definitions

• Fraud: Any intentional act of deception, misrepresentation, concealment, or manipulation of financial records or transactions for personal gain or to benefit a third party at the expense of the Foundation.
• Corruption: The abuse of a position of trust or authority for private gain, including bribery, extortion, kickbacks, and nepotism.
• Bribery: Offering, giving, receiving, or soliciting anything of value to influence the actions of a person in a position of authority.

3.3 Anti-Bribery Commitment

The Foundation strictly prohibits the payment or acceptance of bribes in any form — whether cash, gifts, services, or other benefits — to or from any individual, government official, partner organisation, or third party. This prohibition applies in all circumstances, including situations where a bribe might be demanded as a prerequisite for receiving a permit, licence, or access to a service.

• No Personnel may authorise or participate in any bribe payment on behalf of the Foundation.
• Any demand for a bribe received from a government official or other party must be reported immediately to Foundation leadership.
• Facilitation payments — small unofficial payments made to expedite routine government actions — are also prohibited.

3.4 Financial Controls

The Foundation maintains rigorous financial controls to prevent and detect fraud and corruption, including:

• Dual authorisation requirements for all expenditures above defined thresholds.
• Separation of duties between those who authorise, execute, and record financial transactions.
• Regular internal and external audits of all accounts, including donor-restricted funds.
• Maintenance of complete, accurate, and auditable financial records in accordance with internationally accepted accounting standards.
• Procurement processes that are transparent, competitive where appropriate, and free from undisclosed conflicts of interest.
• Cash handling procedures that minimise the risk of theft or unrecorded disbursements.

3.5 Donor Fund Management

Funds restricted by a donor for a specific programme or purpose will be used exclusively for that purpose. The Foundation will:

• Maintain separate accounting records for all restricted grants.
• Report financial expenditures to donors accurately and within the timeframes specified in grant agreements.
• Immediately notify relevant donors of any suspected misuse of their funds.
• Return unspent restricted funds or seek donor approval before applying them to any alternative purpose.

3.6 Consequences

Any Personnel found to have engaged in fraud or corruption will face immediate suspension pending investigation, followed by termination of employment or engagement and, where warranted, referral to law enforcement authorities. The Foundation will pursue recovery of misappropriated funds through all legal means available.

The Foundation recognises that speaking up about suspected misconduct takes courage. We are committed to making it safe for anyone — staff, volunteers, partners, beneficiaries, or members of the public — to raise concerns about violations of our Code of Conduct, Safeguarding Policy, or Anti-Fraud & Corruption Policy.

4.1 Who Can Report

Any person may submit a report, including:

• Current and former Foundation Personnel (staff, consultants, volunteers, interns).
• Personnel of partner organisations and contractors.
• Beneficiaries of Foundation programmes, or their family members and community representatives.
• Donors, government officials, or any member of the public who has reason to believe a violation has occurred.

4.2 What to Report

Reports should relate to suspected or actual violations of any Foundation policy, including but not limited to:

• Abuse, exploitation, or harassment of a child or vulnerable adult.
• Sexual exploitation or sexual misconduct by Foundation Personnel.
• Fraud, theft, or misappropriation of Foundation funds or assets.
• Bribery, corruption, or undisclosed conflicts of interest.
• Discriminatory conduct or serious violations of the Code of Conduct.
• Any conduct that poses a risk to the safety, health, or rights of beneficiaries or Personnel.

4.3 How to Report

Reports may be submitted through the following channels. Reports can be made anonymously. Reporters are not required to provide their name or contact details, though doing so may assist in the investigation.

4.4 Non-Retaliation Guarantee

The Foundation strictly prohibits retaliation against any person who, in good faith, reports a suspected violation of Foundation policies or participates in an investigation. Retaliation includes, but is not limited to:

• Termination or demotion of employment.
• Threats, intimidation, or harassment.
• Any adverse change to working conditions or programme participation.

Any person who retaliates against a whistleblower will themselves be subject to disciplinary action, up to and including termination and legal referral. If you believe you have experienced retaliation after making a report, please contact Foundation leadership immediately at admin@stmaryseduhealth.org.

4.5 How Reports Are Handled

All reports of misconduct are handled according to the following process:

1. Receipt & Acknowledgement: All reports are received and logged. Where a reporter has provided contact details, an acknowledgement will be sent within 5 working days.
2. Initial Assessment: Foundation leadership will conduct an initial assessment within 10 working days to determine the seriousness of the allegation and the appropriate response, which may include an immediate interim safeguarding measure if a child or vulnerable adult is at risk.
3. Investigation: Substantive allegations will be investigated by designated personnel who are independent of the subject of the complaint. Investigations will be conducted impartially, confidentially, and with due respect for all parties involved.
4. Escalation: Where an allegation may constitute a criminal offence — particularly in relation to child safeguarding or serious fraud — the Foundation will notify relevant government authorities in South Sudan and, where required, the relevant funding agency or donor.
5. Outcome: Findings will be documented and appropriate action taken. Where possible and appropriate, the reporter will be informed of the general outcome of the investigation.
6. Record-Keeping: All reports and investigation records are retained securely for a minimum of seven years in accordance with good governance practice.

St. Mary's Global Foundation maintains a zero-tolerance policy toward sexual exploitation, sexual abuse, and all forms of harassment or misconduct by any personnel toward beneficiaries. The Foundation recognises its duty of care to all persons served by its programs — most especially children and other vulnerable populations in South Sudan.

5.1 Who Is Protected

This policy protects all beneficiaries of SMGF programs — including children, women, internally displaced persons, persons with disabilities, and any individual in a vulnerable situation who interacts with the Foundation's programs in South Sudan or wherever the Foundation operates.

5.2 Who Is Bound

This policy binds all SMGF personnel: Board members, Executive Director, management, staff, volunteers, consultants, contractors, and implementing partners — in all settings including field operations, offices, travel, and remote work.

5.3 Prohibited Conduct

The following conduct is absolutely prohibited and constitutes grounds for immediate termination and law enforcement referral:

• Sexual exploitation, sexual abuse, or sexual harassment of any beneficiary
• Transactional sex — exchanging money, goods, or assistance for sexual favors
• Any sexual or romantic relationship with a current beneficiary
• Any sexual act, contact, or grooming involving a child beneficiary
• Conditioning program access or assistance on sexual compliance
• Physical, emotional, or psychological abuse of beneficiaries

5.4 Reporting Concerns

Anyone — including beneficiaries, community members, or staff — may report PSEA concerns. Anonymous reports are accepted and taken seriously. Reports are treated with strict confidentiality:

• Email: info@stmaryseduhealth.org or admin@stmaryseduhealth.org
• Community suggestion boxes at all program sites
• Direct reporting to the PSEA Focal Point or Executive Director

5.5 Special Protections for Children

All personnel working directly with children undergo background checks and specialized child safeguarding training. No SMGF personnel may be alone with a child beneficiary without another adult present. Child-involving activities take place in visible, supervised locations. Reporting obligations for child victims are mandatory under the South Sudan Child Act 2008.

The Constitution of St. Mary's Global Foundation for Education and Health is the supreme governing document of the organisation. It establishes the legal framework, governance structures, financial management principles, and ethical standards that guide all operations of the Foundation.

Document Reference: SMGF-CONST-001 v1.0

The Constitution covers the following Articles:

• Article I: Name & Legal Status — registered in Juba, South Sudan
• Article II: Vision, Mission & Objectives — education access, community health, partnerships
• Article III: Membership — categories, rights, obligations, and termination
• Article IV: Board of Directors — composition, election, terms, powers, meetings, and quorum
• Article V: Officers — Executive Director/CEO, Deputy Executive Director
• Article VI: Organisational Structure — departments and organogram reference
• Article VII: General Assembly & Meetings — AGM, EGM, voting procedures
• Article VIII: Financial Management — fiscal year, banking, audit, asset management
• Article IX: Amendments — proposal and approval process
• Article X: Dissolution — process and asset distribution
• Article XI: Conflict of Interest — disclosure and recusal
• Article XII: Indemnification — protection of officers and directors
• Article XIII: Miscellaneous — governing law, severability, effective date

The Constitution was adopted on 21 March 2026 and constitutes the foundation for all supplementary policies, including the Financial Policy, HR Policy, Safeguarding Policy, Anti-Fraud Policy, PSEA Policy, and Whistleblower Policy.