Zero tolerance for unethical, illegal, and fraudulent acts policy

Introduction and purpose

Upinion is committed to maintaining the highest standards of ethical conduct, legality, and integrity in all aspects of its operations.

This Zero Tolerance Policy is designed to ensure that employees, volunteers, suppliers, partners, and stakeholders adhere to the principles of honesty, transparency, and responsibility in their actions while representing Upinion.

This document can be found online on:

Zero tolerance

Upinion strictly prohibits any form of unethical, illegal, or fraudulent behavior. Violations of this policy will result in immediate disciplinary action, up to and including termination of employment or business relationships.

Examples of prohibited conduct

  • Fraudulent activities:
    • Any form of misrepresentation, falsification, or manipulation of information
    • Intentional deception in financial transactions, reporting, or communications
  • Unethical behavior:
    • Conflict of interest without proper disclosure
    • Harassment, discrimination, or any form of unfair treatment
    • Corruption in any form, such as bribery, extortion, and abuse of power
  • Illegal activities:
    • Violation of local, national, or international laws
    • Any practice inconsistent with the rights set forth in the Convention on the Rights of the Child or the six core principles for Protection from Sexual Exploitation and Abuse in Humanitarian Crises. 
    • Participation in activities that undermine public trust


To achieve the prevention of fraudulent activity, unethical behavior, and illegal activity within the organization, the following preventive measures shall be implemented:


Upinion follows procedures when engaging with different types of stakeholders. The social enterprise follows the following procedures when it enters into any type of service agreement: 

  • Screening and Hiring of Employment Procedure for employees 
  • Screening and Onboarding of Volunteers Procedure for volunteers
  • Procedure for Purchasing and Evaluation of Suppliers for suppliers

These policies also contain procedures for screening all individuals and legal entities through, which integrates data from over a 100 global sources, including official sanctions lists, data on politically exposed persons and entities of criminal interest. 

Code of Conduct

All individuals associated with Upinion, including employees, contractors, partners, volunteers, and board members, are required to adhere to a comprehensive Code of Conduct. This code outlines the principles of honesty, integrity, and ethical behavior expected from each member.

Training and Awareness Programs

Upinion will conduct regular training sessions and awareness programs to educate individuals on recognizing, preventing, and reporting fraudulent, unethical, and illegal activities. These programs will ensure that all members of the organization are well-informed about the policies and ethical standards.

Conflict of Interest Policy

A Conflict of Interest Policy will be maintained to identify and manage situations where personal interests may conflict with the interests of the organization. Transparency and proper disclosure of potential conflicts of interest are vital to maintaining ethical standards.

Regular review and assessment

The organization will conduct regular reviews and assessments of its policies and procedures to identify and address potential vulnerabilities to fraudulent, unethical, and illegal activities. 

Any necessary updates or improvements will be implemented to enhance the effectiveness of prevention measures.

Reporting violations 

Upinion encourages a culture of accountability and transparency, and individuals who become aware of potential violations are urged to report such incidents promptly. Reporting can be done through the following channels:

  • Internal channels:
    • Direct supervisor or manager
    • Executive Board
    • Supervisory Board
    • Incident Report Form
      • ​​Can be done anonymously
    • Dedicated whistleblowing email address
  • External channels:
    • Whistleblower Service
      • You can contact the external Whistleblower Service, Het Huis voor Klokkenluiders via +31 (0)88 1331 030 or [email protected].

Investigation and consequences

In case of an allegation of a violation, Upinion follows the Quality Incidents & Complaints Management Procedure which outlines all necessary steps:

  1. Receipt of Complaint:
    1. The complaint should be raised either through the specified internal channels like direct supervisors, the Executive Board, or Supervisory Board, using the Incident Report Form, or through the designated whistleblowing email address.
    2. External channels such as the Whistleblower Service or External Confidential Counsellors can also be used where applicable.
  2. Classification and Logging:
    1. Every allegation is classified by an executive board member according to its seriousness (Quality weakness or event, Minor incident, Major incident).
    2. The incident is logged in the Registry of Quality Incidents & Complaints and communicated within the Slack Channel #quality-incidents with a 👀 emoji signifying it has been noticed and will be addressed.
  3. Investigation:
    1. The executive board analyses the incident, establishes the cause, takes containment measures, and suggests preventive and/or corrective actions.
    2. For major incidents, additional steps are taken, such as informing the executive board and assigning a lead executive to the case.
    3. The main communication regarding incident treatment is agreed upon.
  4. Evidence Collection:
    1. The CEO or designated individuals will identify, collect, and preserve evidence according to predefined rules, ensuring a proper chain of custody and protection against unauthorised access or tampering.
  5. Communication:
    1. If the reporter has opted to be contacted, the executive board will acknowledge receipt of the complaint, gather additional information, and provide updates on the status of the investigation.
  6. Review and Learning:
    1.  The CEO analyses each incident and, if necessary, suggests further preventive or corrective action to prevent recurrence.
    2. Reported incidents will be shared with the supervisory board periodically.
  7. Disciplinary Actions:
    1. In accordance with the severity of the offence, a range of disciplinary actions from verbal warnings to discharge may be implemented.
  8. Legal Actions:
    1. Based on the evidence collected and the gravity of the incident, legal authorities may be consulted and appropriate legal action may be taken.


All individuals associated with Upinion are required to read, understand, and strictly adhere to this Zero Tolerance Policy. Failure to comply may result in serious consequences, reflecting Upinion’s unwavering commitment to maintaining the highest ethical standards in its operations.

Review and revision

This policy will be reviewed periodically and updated as needed to ensure its effectiveness and alignment with best practices.


The Zero Tolerance for Unethical, Illegal, and Fraudulent Acts Policy Policy is effective as of 26 September 2023 and has been adopted by Upinion’s Executive Board.