Misconduct Policy and Procedure

Last Edited 18 April 2024 18:37 CEST


The purpose of this document is to outline the procedure for reporting misconduct in the scope of ICM’s work. Reports can be made by anyone who is concerned about misconduct including programme participants, suppliers, partners and members of the public, and by ICM staff (employees, contractors, consultants, and volunteers). 

Misconduct is conduct or behaviour that goes against ICM’s Code of Conduct and related policies when committed by anyone working within ICM’s scope of work. This includes misconduct within ICM member associations who are carrying out programmatic work funded by or through ICM or other persons or entities with a contractual relationship with ICM. Misconduct includes bullying and harassment, fraud, bribery, exploitation, money laundering, diversion of funds, and conflict of interest.  

In case the concern is about ICM’s organisational practices (such as criminal activity, danger to health and safety, breach of legal obligations etc), it is advised to seek guidance in ICM’s Whistleblowing Policy and Whistleblowing Procedure. 

Concerns or complaints by ICM Employees about their employment with ICM should be addressed through the ICM Grievance Policy and Procedure. Harassment or bullying between ICM staff should be addressed through the Bullying and Harassment Policy. 

Stage 1 

Where appropriate, it is encouraged to report the misconduct to the relevant ICM contact (for example the Project Coordinator or Head of Programmes and Partnerships) in the first instance, whether orally, or in writing. Details of the misconduct should be included, such as when and where the incident(s) took place, who was involved and what happened or is suspected to have happened. The report will be kept confidential, in line with ICM’s Confidentiality Policy.

The ICM contact and the informant will discuss the report and solutions and options for resolution. The objective of the ICM contact is to work together with the informant to understand if the report can be resolved through conversation or facilitated discussions, or if the report needs to be escalated and formally investigated under Stage 2. If it can be resolved under Stage 1, the objective is to resolve it within 14 days of its submission, although depending on the complexity, it may take longer.

If the report cannot be addressed through the Stage 1 process, there are structured processes to address reports of misconduct, which ensure fair treatment of all parties involved. Note that ICM cannot address anonymous reports. 

Stage 2 

A written statement of the possible misconduct, together with any steps already taken to try to resolve it (if applicable) can be submitted: 

  • Via email to the relevant ICM Project Coordinator or Head of Programmes and Partnerships 
  • Via email to [email protected]  
  • By post to International Confederation of Midwives, Koninginnegracht 60, 2514 AE, The Hague 

Submissions should be marked as Confidential.  

The written statement should include: 

  • What alleged misconduct is being reported? Describe what happened, including as many details as possible. 
  • Who committed the alleged misconduct? Was anyone else was involved? Provide full names, titles and organisation, if possible. 
  • When and where did the incident(s) happen? Indicate date(s) and time(s), if available. 
  • How did the individual commit the alleged misconduct? 
  • Why do you believe the activity is misconduct? 
  • If you have any supporting evidence (evidence to be provided later) and names of any other potential witnesses 

Following receipt of the report, the most appropriate ICM contact will register the complaint and conduct a preliminary assessment to determine whether an investigation is warranted, considering whether the issue falls within ICM’s mandate and whether the alleged facts could amount to misconduct.  They will arrange a meeting within 7 working days to discuss the report and seek to resolve it. If resolution is outside the scope of the ICM Head Office team contact, the report will be referred to Stage 3 and the informant will receive notification of the reasons for this.


Stage 3

If the written report is deemed to fall within ICM’s mandate and that the alleged incident(s) could amount to misconduct, then an external investigator will be appointed. 

The investigative process will consist of the following steps: 

  1. Planning
  2. Evidence gathering
  3. Analysing
  4. Concluding and next steps


The full process is outlined in the ICM Investigations Procedure.  

The objective is to complete the Investigation Procedure within 28 days. If it is a complex investigation, it may take longer, the informant will be notified of the anticipated timescale. 

Following completion of the Investigation Procedure, the informant will be notified of the outcome of the investigation. 



This Policy and Procedure will be reviewed every three years, and any changes in good practice and/or legislation will be incorporated.   

Other Related Documents 

  • Anti Fraud, Bribery and Corruption Policy 
  • Anti Money Laundering Policy & Procedure 
  • Bullying and Harassment Policy 
  • Code of Conduct  
  • Confidentiality Policy 
  • Disciplinary Procedure 
  • Grievance Policy and Procedure 
  • Investigations Procedure 
  • Whistleblowing Policy 
  • Whistleblowing Procedure


Document Control 

Approved by  Chief Executive 
Responsible Owner  Head of Organisational Projects 
Created  December 2023 
Approved  18 April 2024 
Next Review  April 2027 
Version  1.0  





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