Privacy, accessibility, and other policies

Birds Canada strives at all times to provide its services in a way that respects the dignity and independence of people with disabilities. We are also committed to giving differently-abled people the same opportunity to access our services, in the same place and in a similar way as other customers. Review our service policies by selecting the following documents:

Accessibility Plan

Message from the President

Birds Canada is committed to treating all people in a way that allows them to maintain their independence and dignity. We believe in integration and equal opportunity. Therefore, we are committed to meeting the needs of people with disabilities in a timely manner, and will do so by planning to avoid barriers to accessibility, removing existing barriers as they are identified, and meeting the accessibility requirements under the Accessibility for Ontarians with Disabilities Act, 2005 (AODA).

Statement of Commitment

Birds Canada strives to meet the needs of its employees and customers with disabilities and is working hard to remove and prevent barriers to accessibility. Our organization is committed to fulfilling our requirements under the Accessibility for Ontarians with Disabilities Act. This accessibility plan outlines the steps we are taking to meet those requirements and to improve opportunities for people with disabilities. Our plan shows how we will play our role in making Ontario an accessible province for all Ontarians.

Customer Service

Birds Canada is committed to providing accessible customer service to people with disabilities. This means that we will provide goods and services to people with disabilities with the same high quality and timeliness as others.

Birds Canada has developed and posted a Customer Service Policy and Customer Service Feedback form that are available in other formats, upon request. All feedback received, as per policy, was reviewed and addressed within 10 business days.

Mandatory training was completed by all Ontario employees and volunteers, as well as all active board members. Customer Service Training is a mandatory part of new hires in Ontario. Training is provided in multiple formats. Birds Canada maintains record of completed training.

Birds Canada provides staff (ON), volunteers and board members with training on the AODA requirements as well as training on the Ontario Human Rights Code (with respect to people with disabilities). The training will be appropriate to the duties of the employees, volunteers or other persons. Training is updated and modified as necessary.

Information and Communications

Birds Canada is committed to meeting the communication needs of people with disabilities. When requested, we will consult with people with disabilities to determine their information and communication needs.

Birds Canada will ensure that existing feedback processes are accessible to people with disabilities upon request.

Birds Canada’s new website and content on this site conform to WCAG 2.0, Level A, except where it is impracticable.

Birds Canada will work toward making its website, and all web content, conform to WCAG 2.0, Level AA, by January 1, 2021, except where it is impracticable.

Accessible Emergency Information

We are committed to providing customers and employees with publicly available emergency information in an accessible format, upon request. Individualized plans are developed for employees requiring accommodations.

Employment

Birds Canada is committed to fair and accessible employment practices.

Birds Canada will notify the public and internal applicants, that when requested, we will accommodate people with disabilities during the recruitment, assessment and hiring process, where available.

When notified by an employee with a disability, Birds Canada will meet with the employee to provide, or arrange for the provision of accessible formats or communication supports for materials the employee needs to perform their job and information that is generally available to other employees.

Birds Canada will ensure accessibility needs of employees with disabilities are taken into account during performance management, career development and redeployment processes.

Birds Canada has developed an Accommodation Policy that supports the development of individual accommodation plans and return to work policies for employees with accessibility needs.

For More Information

For more information on this accessibility plan, or for a copy of this plan in an accessible format, please contact Katie Ardeline by phone: 519-586-3531, facsimile: 519-5863532, email: kardeline@birdscanada.org , or by regular mail: P.O. Box 160, Port Rowan, ON N0E 1M0.

 

Integrated Accessibility Standard Regulation Policy

Statement of Commitment

Birds Canada is committed to treating all people in a way that allows them to maintain their dignity and independence. We are committed to meeting the needs of people with disabilities in a timely manner, and will do so by preventing and removing barriers to accessibility and meeting accessibility requirements under the Accessibility for Ontarians with Disabilities Act.

Training

Birds Canada is committed to training Ontario staff and volunteers on Ontario’s accessibility laws and on accessibility aspects of the Ontario Human Rights Code that apply to persons with disabilities. Training will be provided in a way that best suits the duties of employees, volunteers, and Board of Directors.

Kiosks

Birds Canada will consider the needs of people with disabilities when designing, procuring or acquiring self- service kiosks.

Information and communications

Birds Canada is committed to meeting the communication needs of people with disabilities. When asked, we will provide information and communications materials in accessible formats or with communication supports. This includes publicly available information about our goods, services and facilities, as well as publicly available emergency and safety information.

Birds Canada will consult with people with disabilities to determine their information and communication needs.

We will ensure existing feedback processes are accessible to people with disabilities upon request.

We will work to make Birds Canada’s website and content conform with regulation (i.e., WCAG 2.0, Level AA) by January 1, 2021.

Employment

Birds Canada is committed to fair and accessible employment practices.

We will notify the public and staff that, when requested, we will accommodate disabilities during recruitment and assessment processes and when people are hired.

If needed, we will create an individual accommodation plan and/or workplace emergency information for any employees who have a disability.

Our performance management, career development, redeployment, and return-to-work processes will take into account the accessibility needs of employees with disabilities.

Design of Public Spaces

Birds Canada will meet the Accessibility Standards for the Design of Public Spaces when building or making major modifications to public spaces including:

• Service-related elements like service counters, fixed queuing lines and waiting areas

• Outdoor paths of travel, like sidewalks, ramps, stairs, curb ramps, rest areas and accessible pedestrian signals

• Accessible off street parking • Recreational trails

• Outdoor public eating areas like rest stops or picnic areas In the event of a service disruption, we will notify the public of the service disruption and alternatives available.

Modifications to this or other policies

Any of our policies that do not respect and promote the dignity and independence of people with disabilities will be modified or removed.

For More Information

For more information on this policy, please contact Katie Ardeline by phone: 519-586-3531, facsimile: 519-5863532, email: kardeline@birdscanada.org , or by regular mail: P.O. Box 160, Port Rowan, ON N0E 1M0.

Accessible formats of this document are available free upon request.

Feedback

Please let us know how we may assist you at Birds Canada. Your feedback is important to us. Your comments will be reviewed by our Chief Financial Officer, who will provide a response to your concern within 1-2 weeks time. This form is available as a printable pdf.

Policy Purpose

The purpose of this policy is to set out Birds Canada’s minimum standards for ensuring human rights are respected and promoted in Birds Canada’s operations and programming.

Scope

This policy applies to all Birds Canada Board of Directors, Committees of the Board and all related personnel and volunteers:

• All staff employed or contracted by Birds Canada in any capacity;
• Related personnel includes those engaged with work or site/program visits related to Birds Canada, including but not limited to the following: board members, consultants; volunteers; the media, journalists, researchers, family members, donor representatives, and
• Related personnel also includes non-Birds Canada entities and their employees and individuals who have entered into partnership, sub-grant or sub-recipient agreements with Birds

Policy Statement

Birds Canada is dedicated to upholding and promoting human rights in all aspects of its operations. We recognize the inherent dignity and equal rights of all individuals and are committed to creating an inclusive, diverse, and respectful environment where human rights are protected and upheld. Birds Canada also recognizes that the environment is essential to the wellbeing of humans. The right to a healthy environment was declared by the United Nations General Assembly and is recognized nationally in many constitutions and laws. Conservation of birds and sustainable use of natural resources must seek solutions that balance the relationship between human rights and nature.

Definitions

Human Rights: Human rights are rights inherent to all human beings, regardless of race, sex, nationality, ethnicity, language, religion, or any other status.

Policy Details

Core Principles

Dignity and Respect:

• Birds Canada values and respects the inherent dignity of every individual. We are committed to treating all people with respect, fairness, and courtesy, irrespective of their race, color, ethnicity, religion, gender, sexual orientation, gender identity, disability, or any other characteristic. Birds Canada commits to respecting internationally proclaimed human rights as included in the Universal Declaration of Human Rights. Birds Canada commits to supporting the needs, aspirations, and rights of Indigenous Peoples to care for the land including the full claiming of their rights as detailed by the UN Declaration on the Rights of Indigenous Peoples (UNDRIP).

Non-Discrimination:

• Discrimination on the basis of race, color, ethnicity, religion, gender, sexual orientation, gender identity, disability, or any other protected characteristic is strictly prohibited within our organization. All individuals will be treated equally and

Freedom and Security:

• Birds Canada is committed to supporting the fundamental freedoms and security of all individuals associated with our organization. We oppose any form of coercion, violence, or abuse and will take prompt action to address such

Workplace Equality:

• Birds Canada is dedicated to providing a workplace free from discrimination and harassment. See Birds Canada’s Violence and Harassment

Child and Vulnerable Adult Protection:

• Birds Canada is committed to protecting the rights and well-being of children and vulnerable adults. We will implement and adhere to robust safeguarding policies and procedures to prevent any form of exploitation, abuse, or neglect. See Birds Canada’s Safeguarding Policy.

Freedom of Expression:

• Birds Canada recognizes and supports the right to freedom of expression. We encourage open and respectful dialogue, fostering an environment where diverse perspectives are

 

Privacy and Data Protection:

• Birds Canada is committed to protecting the privacy and personal data of individuals associated with our organization. Birds Canada will comply with applicable data protection laws and ensure that all personal information is handled responsibly and securely.

Community Engagement:

• Birds Canada will actively engage with the communities we serve, respecting their cultural, social, and economic rights. Birds Canada will work collaboratively with stakeholders to address human rights concerns within the scope of our work and contribute positively to the well-being of the

Continuous Improvement:

• Birds Canada is dedicated to regularly reviewing and improving its human rights policies and practices. Feedback from employees, volunteers, and stakeholders will be sought, and appropriate measures will be taken to address any identified areas for

 

Compliance and Monitoring

Reporting of Human Rights Concerns

Birds Canada will ensure that safe, appropriate, accessible means of reporting Human Rights concerns are made available to staff and the communities we work with.

How to report a suspected concern

Staff members who have a complaint or concern relating to suspected violations of the Birds Canada Human Rights policy should report it immediately to their Manager or Supervisor. If the staff member does not feel comfortable reporting to their Manager or Supervisor, (for example if they feel that the report will not be taken seriously or if that person is implicated in the concern) they may report to any other appropriate senior manager, or confidentially to Human Resources at: reporting@birdscanada.org.

Birds Canada will also accept and follow up on complaints from external sources such as project beneficiaries and other members of the public, partners and official bodies. Reporting should be directed confidentially to Human Resources at: reporting@birdscanada.org. In the event of an unresolved concern at the staff level, the Board of Directors will be notified for further action.

Response

Birds Canada will follow up Human Rights reports and concerns according to policy and procedure, and legal and statutory obligations.

Birds Canada will apply appropriate disciplinary measures to staff found in breach of policy.

In the event that reports involve partners or sub-contractors, Birds Canada will entrust relevant representatives or leadership of these organizations with ensuring appropriate investigation and response mechanisms. Birds Canada will monitor whether these are advanced and ensure the application of terms included in partnership, sub-grant or sub-recipient agreements related to Human Rights. If these processes are not fulfilled – or fulfilled in a manner inconsistent with relevant legal and statutory obligations and principles – Birds Canada will note that a breach in sub-contractual agreements has occurred and apply actions including, but not limited to, the temporary or permanent dissolution of partnership, sub-grant or sub-recipient agreement.

Policy Purpose

The purpose of this policy is to outline Birds Canada’s commitment to promoting gender equality within our organization and the broader conservation community.

Scope

This policy applies to all Birds Canada Board of Directors, Committees of the Board and all staff.

Policy Statement

Birds Canada is committed to fostering a workplace culture that embraces diversity and ensures gender equality in all aspects of our work. Birds Canada also recognizes that a gender-responsive approach is essential for achieving our mission and is integral to creating a more sustainable and equitable world. Birds Canada understands that women and men often have different access to and impacts on the environment, and that the importance of gender mainstreaming to achieve conservation outcomes is recognized by several international instruments, including the Convention on Biological Diversity. Birds Canada supports the equal realization of rights for girls, women, boys, and men and individuals who self-identify as 2SLGTBQI+ as employees, donors, partners, beneficiaries, and other stakeholders in its work.

Definitions

Gender: The term gender refers to an individual’s personal or social identity as a man, woman or non-binary person (a person who does not identify exclusively as a man or a woman). These attributes, opportunities, and relationships are socially constructed and are learned through socialization processes and can be the basis for gender identity and gender expression.

Gender equality: Gender equality refers to the equal rights, responsibilities, and opportunities of women, men, girls, boys and individuals who identify as 2SLGBTQI+ or non-binary persons.

Equality does not mean that women, men, 2SLGBTQI+ and other non-binary persons will become the same but that their responsibilities and opportunities will not depend on the sex recorded at birth.

Gender mainstreaming: Gender mainstreaming involves ensuring that attention to gender equality is a central part of all environmental and sustainable development interventions, including analyses, policy advice, advocacy, legislation, research, and the planning, implementation, monitoring and evaluation of programs and projects.

Policy Details

Core Principles

Equal Opportunities:

• Birds Canada is dedicated to providing equal opportunities for all individuals, regardless of gender. Birds Canada will ensure that our recruitment, training, promotions, and other employment-related decisions are based on merit and qualifications, fostering an environment of equal access and

 

Inclusive Work Environment:

• Birds Canada strives to create an inclusive work environment, including via appropriate accommodations, where all employees, volunteers, and stakeholders feel valued and respected, irrespective of their gender identity or expression. Discrimination or harassment based on gender will not be tolerated (see Birds Canada’s Violence and Harassment Policy).

 

Gender-Responsive Policies and Practices:

• Birds Canada will periodically review and assess its policies and practices to ensure they are gender-responsive. This includes considering the diverse needs and perspectives of individuals of all genders in program development, decision-making processes, and resource

 

Work-Life Balance:

• We recognize the importance of work-life balance for all individuals. Birds Canada will explore and implement flexible work arrangements, where feasible, to accommodate the diverse needs of employees and volunteers, considering family responsibilities and other personal

 

Training and Capacity Building:

• Birds Canada is committed to supporting its employees in training and capacity- building opportunities that promote gender equality, diversity, and inclusion. See Birds Canada’s Inclusion, Diversity, Equity and Accessibility Committee Terms of Reference and Action

 

Gender-Responsive Conservation:

• In our conservation work, Birds Canada will consider and integrate gender- responsive approaches. This includes recognizing the unique roles and contributions of individuals of all genders in the places where we work and implications for

 

conservation of birds. Birds Canada will support the empowerment of women and girls as a key strategy towards the conservation of birds. Birds Canada will ensure equitable access to benefits from its resources, knowledge, and services for women, men and 2SLGBTQI+ individuals.

 

Gender Pay Equity:

• Birds Canada is committed to ensuring gender pay equity. We conduct regular reviews of our Compensation Framework to identify and rectify any gender-based pay gaps, promoting fair and equal remuneration for all

 

Leadership Commitment:

• The leadership team at Birds Canada is committed to championing gender They will actively work towards creating an organizational culture that values diversity, promotes inclusivity, and empowers individuals of all genders.

 

Monitoring and Reporting:

• Birds Canada will establish mechanisms to monitor and report on progress towards gender equality goals. Periodic reports will be shared with stakeholders to demonstrate our commitment and accountability in this

Policy Purpose

The purpose of this policy is to protect people, particularly children, at risk adults and beneficiaries of assistance, from any harm that may be caused due to their coming into contact with Birds Canada. This includes harm arising from:

• The conduct of staff or personnel associated with Birds Canada
• The design and implementation of Birds Canada’s programs, projects and activities

The policy lays out the commitments made by Birds Canada, and informs staff and associated personnel of their responsibilities in relation to safeguarding.

This policy does not cover:

• Sexual harassment in the workplace – this is dealt with via Birds Canada’s Violence and Harassment Policy
• Safeguarding concerns in the wider community not perpetrated by Birds Canada or associated personnel

 

Scope

This policy applies to all Birds Canada Board of Directors, Committees of the Board, all employees, volunteers, and related personnel:

• All staff employed or contracted by Birds Canada in any capacity;
• Related personnel includes those engaged with work or site/program visits related to Birds Canada, including but not limited to the following: board members, consultants; volunteers; the media, journalists, researchers, family members, donor representatives, and

 

• Related personnel also includes non-Birds Canada entities and their employees and individuals who have entered into partnership, sub-grant or sub-recipient agreements with Birds

 

Policy Statement

Birds Canada believes that everyone we come into contact with, regardless of age, gender identity, disability, sexual orientation or ethnic origin has the right to be protected from all forms of harm, abuse, neglect and exploitation. Birds Canada will not tolerate abuse and exploitation by staff or associated personnel.

This policy will address the following areas of safeguarding [as appropriate]: child safeguarding, adult safeguarding, and protection from sexual exploitation and abuse.

Birds Canada commits to addressing safeguarding throughout its work, through the three pillars of prevention, reporting and response.

Definitions

Beneficiary of Assistance: Someone who directly receives goods or services from Birds Canada’s program. Note that misuse of power can also apply to the wider community that the NGO serves, and can include exploitation by giving the perception of being in a position of power.

Child: A person below the age of 18

Grooming: Grooming generally refers to behaviour that makes it easier for an offender to procure a child or vulnerable adult for sexual activity. It often involves the act of building the trust of children and/or their carers or a vulnerable adult, to gain access to them in order to sexually abuse them. For example, grooming includes the provision of, or attention paid to a specific child or adult, providing gifts, money, drugs or alcohol to them, encouraging romantic feelings or exposing them to sexual concepts through conversation or exposure to pornography.

Online grooming is the act of sending an electronic message, series of messages or engaging over an online platform with content that may be of an indecent nature, with the intention of procuring the recipient to engage in or submit to sexual activity with another person, including but not necessarily the sender.

Both children and vulnerable adults can be victims of grooming and online grooming, with children being particularly targeted by online groomers.

Harm: Psychological, physical and any other infringement of an individual’s rights

Psychological Harm: Emotional or psychological abuse, including (but not limited to) humiliating and degrading treatment such as bad name calling, constant criticism, belittling, persistent shaming, solitary confinement and isolation

Protection from Sexual Exploitation and Abuse (PSEA): The term used by the humanitarian and development community to refer to the prevention of sexual exploitation and abuse of affected populations by staff or associated personnel. The term derives from the United Nations Secretary General’s Bulletin on Special Measures for Protection from Sexual Exploitation and Abuse.

Safeguarding: Safeguarding means protecting peoples’ health, wellbeing and human rights, and enabling them to live free from harm, abuse and neglect.

In our sector, we understand it to mean protecting people, including children and at-risk adults, from harm that arises from coming into contact with our staff or programs.

Safeguarding means taking all reasonable steps to prevent harm, particularly sexual exploitation, abuse and harassment from occurring; to protect people, especially vulnerable adults and children, from that harm; and to respond appropriately when harm does occur.

Safeguarding applies consistently and without exception across our programs, partners and staff. It requires proactively identifying, preventing and guarding against all risks of harm, exploitation and abuse and having mature, accountable and transparent systems for response, reporting and learning when risks materialize. Those systems must be survivor-centred and also protect those accused until proven guilty.

Safeguarding puts beneficiaries and affected persons at the centre of all we do.

Sexual Abuse: The term ‘sexual abuse’ means the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions.

Sexual Exploitation: The term ‘sexual exploitation’ means any actual or attempted abuse of a position of vulnerability, differential power, or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another. This definition includes human trafficking and modern slavery.

Survivor: The person who has been abused or exploited. The term ‘survivor’ is often used in preference to ‘victim’ as it implies strength, resilience and the capacity to survive, however it is the individual’s choice how they wish to identify themselves.

At Risk Adult: Sometimes also referred to as a vulnerable adult. A person who is or may be in need of care by reason of mental or other disability, age or illness; and who is or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation.

Policy Details

PREVENTION

Birds Canada Responsibilities

Birds Canada will:

• Ensure all staff have access to, are familiar with, and know their responsibilities within this policy
• Design and undertake all its programs and activities in a way that protects people from any risk of harm that may arise from their coming into contact with Birds Canada. This includes the way in which information about individuals in our programs is gathered and communicated
• Implement stringent safeguarding procedures when recruiting, managing and deploying staff and associated personnel
• Ensure staff receive training on safeguarding at a level commensurate with their role in the organization
• Follow up on reports of safeguarding concerns promptly and according to due process

 

Staff Responsibilities

Child safeguarding

Birds Canada staff and associated personnel must not:

• Engage in sexual activity with anyone under the age of 18
• Sexually abuse or exploit children
• Subject a child to physical, emotional or psychological abuse, or neglect
• Engage in any commercially exploitative activities with children including child labour or trafficking
• Engage in grooming of children

 

Adult Safeguarding

Birds Canada staff and associated personnel must not:

• Sexually abuse or exploit at risk adults
• Subject an at risk adult to physical, emotional or psychological abuse, or neglect
• Subject an at risk adult to grooming practices

 

Protection from Sexual Exploitation and Abuse

Birds Canada staff and associated personnel must not:

• Exchange money, employment, goods or services for sexual activity. This includes any exchange of assistance that is due to beneficiaries of assistance
• Engage in any sexual relationships with beneficiaries of assistance, since they are based on inherently unequal power dynamics

 

REPORTING

Birds Canada will ensure that safe, appropriate, accessible means of reporting safeguarding concerns are made available to staff and the communities we work with.

How to report a safeguarding concern

Staff members who have a complaint or concern relating to safeguarding should report it immediately to their Manager or Supervisor. If the staff member does not feel comfortable reporting to their Manager or Supervisor, (for example if they feel that the report will not be taken seriously, or if that person is implicated in the concern) they may report to any other appropriate senior manager, or confidentially to Human Resources at: reporting@birdscanada.org.

Birds Canada will also accept and follow up on complaints from external sources such as project beneficiaries and other members of the public, partners and official bodies. Reporting should be directed confidentially to Human Resources at: reporting@birdscanada.org. In the event of an unresolved concern at the staff level, the Board of Directors will be notified for

 

further action.

 

RESPONSE

Birds Canada will follow up safeguarding reports and concerns according to policy and procedure, and legal and statutory obligations.

Birds Canada will apply appropriate disciplinary measures to staff found in breach of policy.

In the event that reports involve partners or sub-contractors, Birds Canada will entrust relevant representatives or leadership of these organizations with ensuring appropriate investigation and response mechanisms. Birds Canada will monitor whether these are advanced and ensure the application of terms included in partnership, sub-grant or sub-recipient agreements related to Safeguarding. If these processes are not fulfilled – or fulfilled in a manner inconsistent with relevant legal and statutory obligations and principles of a survivor-centered approach – Birds Canada will note that a breach in sub-contractual agreements has occurred and apply actions including, but not limited to, the temporary or permanent dissolution of partnership, sub-grant or sub-recipient agreement. At all times, decisions related to confidentiality and support will be led by the survivor.

Birds Canada will offer support to survivors of harm caused by staff or associated personnel, regardless of whether a formal internal response is carried out (such as an internal investigation). Decisions regarding support will be made using a survivor-centred approach.

CONFIDENTIALITY

It is essential that confidentiality is maintained at all stages of the process when dealing with safeguarding concerns. Information relating to the concern and subsequent case management should be shared on a need to know basis only, and should be kept secure at all times.

Policy Purpose

The purpose of this policy is to outline Birds Canada’s principles that guide our commitment to preventing corruption, fraud, and bribery within our organization’s operations and programming.

Scope

This policy applies to all Birds Canada Board of Directors, Committees of the Board, and all staff.

Policy Statement

Birds Canada is committed to maintaining the highest standards of integrity, transparency, and accountability. As a not-for-profit organization, Birds Canada recognizes the importance of preventing corruption in all its forms to safeguard our reputation, preserve public trust, and ensure the effective pursuit of our mission.

Definitions

Corruption: The term refers to the misuse of power for private profit or gain.

Fraud: The term describes a whole range of activities such as deception, bribery, forgery, extortion, theft, conspiracy, embezzlement, misappropriation, false representation, concealment of material facts and collusion.

Bribery: The term refers to offering to make or making a payment, or offering to provide anything of value, to influence a decision or process or create an improper disadvantage.

Policy Details

Core Principles

Zero Tolerance for Corruption:

• Birds Canada maintains a zero-tolerance approach towards corruption. Any form of bribery, extortion, fraud, embezzlement, or other corrupt practices is strictly prohibited.

Compliance with Laws:

• Birds Canada will comply with all applicable anti-corruption laws and regulations in the jurisdictions where we operate. This includes the Corruption of Foreign Public Officials Act (CFPOA) and any other relevant national or international legislation in the areas where we work.

Gifts and Hospitality:

• Employees and representatives of Birds Canada shall not offer, give, or receive any gifts, entertainment, or hospitality that could be perceived as intended to influence business decisions or compromise integrity. Transparent gifts of nominal value may be accepted, but larger or more extravagant gifts must be

Conflict of Interest:

• All employees and representatives must disclose any personal or financial interest that may conflict with the interests of Birds Canada. Conflicts of interest will be managed transparently and appropriately to prevent

Financial Controls:

• Birds Canada will implement and maintain robust financial controls to prevent and detect corruption. This includes proactive awareness raising on Birds Canada’s procurement policies, regular audits, segregation of duties, and other measures to ensure the responsible use of

Whistleblower Protection:

• Birds Canada encourages employees, volunteers, and stakeholders to report any suspected corrupt practices. Individuals who come forward in good faith will be protected from

Due Diligence in Partnerships:

• Before entering into partnerships with external entities, Birds Canada will conduct due diligence to assess the integrity and anti-corruption practices of potential partners, vendors, and

Training and Awareness:

• Birds Canada is committed to providing education to employees, volunteers, and stakeholders about anti-corruption policies, laws, and ethical

Continuous Monitoring and Improvement:

• Birds Canada will regularly monitor and assess the effectiveness of this Anti- Corruption

 

Compliance and Monitoring

Reporting of Corruption, Fraud or Bribery Concerns

Birds Canada will ensure that safe, appropriate, accessible means of reporting Corruption, Fraud and Bribery concerns are made available to staff and the communities we work with.

How to report a suspected concern

Staff members who have a complaint or concern relating to suspected violations of the Birds Canada Anti-Corruption, Anti-Fraud and Anti-Bribery Policy should report it immediately to their Manager or Supervisor. If the staff member does not feel comfortable reporting to their Manager or Supervisor, (for example if they feel that the report will not be taken seriously, or if that person is implicated in the concern) they may report to any other appropriate senior manager, or confidentially to Human Resources at: reporting@birdscanada.org. If senior managers and/or the President & CEO are implicated in the concern, the report should be sent to the Chair of the Governance & Nominating Committee.

Birds Canada will also accept and follow up on complaints from external sources such as project beneficiaries and other members of the public, partners and official bodies. Reporting should be directed confidentially to Human Resources at: reporting@birdscanada.org. In the event of an unresolved concern at the staff level, the Board of Directors will be notified for further action.

Response

Birds Canada will follow up on reports of violations of the Birds Canada Anti-Corruption, Anti-Fraud and Anti-Bribery Policy according to policy and procedure, and legal and statutory obligations.

Birds Canada will apply appropriate disciplinary measures to staff found in breach of policy.

In the event that reports involve partners or sub-contractors, Birds Canada will entrust relevant representatives or leadership of these organizations with ensuring appropriate investigation and response mechanisms. Birds Canada will monitor whether these are advanced and ensure the application of terms included in partnership, sub-grant or sub-recipient agreements related to violations of the Birds Canada Anti-Corruption, Anti-Fraud and Anti-Bribery Policy. If these processes are not fulfilled – or fulfilled in a manner inconsistent with relevant legal and statutory obligations and principles – Birds Canada will note that a breach in sub-contractual agreements has occurred and apply actions including, but not limited to, the temporary suspension or permanent dissolution of partnership, sub-grant or sub-recipient agreement.