How to Use the Guidelines

There is no one Prevention of Financial Wrongdoing policy that fits all Non-Government Organisations (NGOs). Accordingly, these guidelines have been developed to support members in developing their own policies in a manner that reflects the particular risk context in which they operate and the level of sophistication of their and their partners’ systems.

An organisation’s Prevention of Financial Wrongdoing policy should reflect the organisation’s activities and programs, locations of work, size, structure and operating model, which in turn all contribute to the risk profile of its operations. The length of the policy and extent of supporting procedural documents is therefore expected to vary across organisations.


  • Carefully consider and assess the risks of financial wrongdoing that apply to your organisation’s operations and systems.
  • Use these guidelines to inform your policy development and review process.
  • Use some of the examples provided in these guidelines if they reflect your organisation’s situation.
  • Identify additional resource requirements which may be required to effectively implement all aspects of your Financial Wrongdoing policy.
  • Consider the laws, customs and culture of the country/area where you are operating and how these may play out in your work.


  • Use these guidelines as a ‘cut and paste’ template for writing your Prevention of Financial Wrongdoing policy. Your policy should be tailored to your organisation.
  • Assume that financial wrongdoing cannot happen within or to your organisation.

The guidelines are divided into two parts:

    1. Steps to develop and implement a Prevention of Financial Wrongdoing Policy;
    2. An overview of the key elements of a good practice Prevention of Financial Wrongdoing policy which incorporates guidelines and tips for the development of each section of the policy.