Summary 

The Media and Migration Association (MMA) takes a firm stance against all forms of bribery and corruption. This anti-corruption policy document outlines the guiding principles and mandatory requirements for preventing, identifying, and addressing corruption within MMA’s management and operations. The policy establishes a framework designed to ensure the highest standards of transparency, accountability, and compliance across all activities and processes. This policy applies to all employees, members, volunteers, service providers, and other stakeholders. The policy ensures that all actions and decisions are conducted ethically, with strict adherence to legal obligations and internal regulations. In instances of corruption or bribery, MMA enforces thorough investigation procedures and appropriate sanctions. The association expects and acts on the principle that all its employees, members, volunteers, bodies, and partner institutions develop a stance against any form of corruption.  Media and Migration Association has zero tolerance for fraud and corruption.

Definitions

Transparency: Transparency refers to a process by which reliable, timely information about existing conditions, decisions and actions relating to the activities of the organization is made accessible, visible and understandable. 

Accountability: Accountability entails the responsible use of power (resources, decision-making), acknowledging the dignity, capacity, and independence of the community in question, through effective and quality programming. Accountability is a structured relationship in which one party has the obligation to ensure that its actions and decisions are evaluated and approved by another. Accountability also implies that there are consequences if an organization fails to fulfil its responsibilities. 

Financial Transparency: Financial transparency describes the level to which an organization offers clear, accurate, and accessible information regarding its financial performance, operations, and position. It includes sharing relevant financial information openly with stakeholders, including employees and regulatory authorities. This transparency can be demonstrated through financial statements, declarations, reports, and disclosures.

Digital Transparency: Digital transparency is defined as a mechanism or condition that allows everyone to search for and access any information or data regarding any resource and sources.

The Personal Data Protection Law: The Personal Data Protection Law (GDPR) was enacted by the Turkish Grand National Assembly on 24 March 2016 and published in the Official Gazette on 7 April 2016, issue no. 29677. As a rule, personal data can only be processed with the explicit consent of the individual and only for a specified purpose.

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1. Introduction

     Media and Migration Association (MMA) acts with the awareness of being accountable to its communities, stakeholders, participants, and volunteers. This policy document has been developed to ensure MGD's activities are conducted within the transparency and accountability framework. MMA operates under this policy and its other policy documents of the association to ensure effective management of its financial resources; act based on ethical principles and ensure accountability to its stakeholders.

   This policy paper outlines the resources and boundaries to be developed by MMA, along with the decision-making authorities, executors, and the responsibilities of all employees and members, as well as the principles and general goals of transparency and accountability efforts. MMA values the principles of openness, transparency, responsiveness, and accountability, which can be achieved through ethical practices, transparency, and accountability towards its stakeholders. These principles form the core approach to managing and conducting its activities within MMA. In this regard, MMA consistently seeks to promote practices and structures that ensure transparent communication and ethical conduct at all levels for its stakeholders. This policy indicates as a guide for ensuring that everyone covered by this policy acts and behaves ethically, responsibly, and transparently. 

   MMA is determined to prevent fraud and deceitful practices by promoting a culture of anti-fraud and anti-corruption among official authorities, external stakeholders, implementing partners, and suppliers. MMA enforces a zero-tolerance approach towards corruption, bribery, and illegal activities.

  2. Purpose and Scope

  The purpose of this policy is to ensure and maintain transparency and accountability in all processes related to the execution of MMA’s activities, projects, and programs. This policy defines MMA’s governing bodies, employees, volunteers, donors, funders, and all stakeholders. The policy document outlines the procedures for managing processes such as fundraising, donation acceptance, procurement, and supplier management.

  The overall scope of this policy is to ensure the effective application of MMA’s transparency and accountability processes, to guarantee the proper communication of information to all stakeholders, and to ensure that MMA operates in accordance with ethical principles. This document aims to provide a foundation for decision-making processes regarding the use of all resources associated with MMA, as well as ethical working practices for employees, third-parties, partners and suppliers in conducting the activities.

  The Transparency and Accountability Policy is implemented in alignment and coordination with the Anti-Bribery and Corruption Policy, which forms a critical and key part of this policy. MMA conducts all its activities in adherence to ethical values and develops mechanisms to prevent unethical behaviours.

    2.1. Principles 

 MMA’s principles of transparency and accountability comprise: 

• Independence and Impartiality: MMA acts fairly and impartially in its operational processes, adhering to the principles of its policy documents, vision, and mission."
• Transparency: The decision-making processes are open and accessible, allowing stakeholders to obtain information that is presented clearly and accurately. All decision-making and financial processes are made publicly available to stakeholders. As an organization governed by the Law on Associations, it submits an annual declaration. Financial reports, activity reports, and dossiers concerning decision-making processes are shared regularly.
• Accountability: MMA's Officials are obligated to explain MMA's activities and outcomes to stakeholders and are held accountable for them. MMA is responsible to its stakeholders for the effective use of financial resources, the results of projects, and the proper management of donations. The accuracy of activities and processes is ensured through internal and external audits.
• Financial Transparency: The clear disclosure of how MMA’s financial resources are used, with these processes subject to auditing and reporting mechanisms.
• Digital Transparency: Ensuring that the information provided by MMA on digital platforms is accessible to everyone and that the accuracy of this information is guaranteed.
• Openness: MMA is accessible through transparent and open communication at every stage. It is committed to learning and growth, continuously adopting a learning-oriented approach to adapt to changing circumstances.
• Non-Discrimination and Equal Opportunities: MMA is committed to providing equal opportunities regardless of gender, sexual orientation, age, cultural and educational background, ethnicity, experience, skills, knowledge, or length of service. MMA will not tolerate any form of discrimination in any aspect
• Access to Information: MMA makes efforts to guarantee that all parties have fair and informed access to the necessary information to participate in MMA's activities and processes, in accordance with relevant confidentiality requirements and personal data protection laws.
• Accessibility: MMA ensures that clear and consistent processes and procedures are provided. It allocates the necessary resources to carry out activities that are accessible and sensitive to disabilities, different ethnic communities, and gender identities. Confidential case management and risk mitigation measures are implemented to ensure secure access.

3. Scope of Application

    This policy applies to all of MMA's management processes, financial activities, projects, fundraising, donations, procurement procedures, and supplier relations. The Administrative Board, board of control, Ethics Committee, employees, suppliers, and members must operate in line with the requirements of this policy.  MMA encourages all parties associated with the organisation to abide by the principles of this policy, adhere to ethical standards when representing or acting on behalf of MMA, and refrain from any behaviour that breaches the transparency and accountability stipulated in this policy paper.

  MMA and all of its affiliated bodies, employees, and service providers are committed to adhering to the highest ethical standards and will not tolerate any form of bribery or corruption. MMA evaluates the following actions under its transparency and accountability policy:

• Financial Transparency and Accountability

• MMA is committed to upholding honesty in its operational processes and ethically conducting all activities. It strives to achieve the highest legal and ethical standards and does not tolerate any form of bribery, corruption, or misconduct.
• MMA ensures transparency and promotes fair competition in all procurement and service delivery processes.
• MMA can receive fund from international organisations, development agencies, consulates, foundations, and individual donors. These resources are reported and declared financially in compliance with legal requirements, contracts, and confidentiality principles.
• Payments to suppliers, service providers, employees, and other beneficiaries are made strictly in line with the terms of agreed contracts.
• In its operations, it is committed to collaborating with relevant stakeholders and partners, aiming to ensure that its partners' funds originate from legitimate sources. It mandates compliance with accounting, record-keeping, and financial reporting requirements in all partnerships and insists on collecting necessary financial and fiscal documentation.

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• Digital Transparency

• MMA conducts all its activities in a transparent manner, ensuring easy access to its charter, policy documents, research, and reports, as well as the sharing of information and methods obtained from research.
• Internet and Information Systems: MMA is responsible for protecting the personal and confidential data of third parties and employees. MA can gather and store employee data in compliance with legal requirements.
• MMA provides internet access, e-mail addresses, and other digital tools to its employees and/or third parties solely for working purposes. All working communications are conducted through electronic communication and e-mail accounts approved by MMA.
• Information and documents are stored in the digital tools and systems designated by MMA during the execution of working processes. It is the responsibility of employees to prevent the sharing of information and documents with third parties outside these systems.
• The social media and digital tool account details used by MMA to promote its activities and operations must not be used for personal gain or any purposes other than their intended use. Email addresses and e-mails are stored in compliance with the Personal Data Protection Law and explicit consent forms.

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4. Responsibilities 

   All MMA employees and members have critical roles and responsibilities in preventing, detecting, and ensuring the immediate management of fraudulent and other illegal practices. All employees and members are responsible for protecting the resources and reputation entrusted to MMA. MMA’s consultants, suppliers, implementing partners, and third parties will be subject to the highest ethical standards. MMA is dedicated to fostering effective and transparent relationships with all stakeholders to create sustainable, long-term value. It seeks to contribute to communities by building relationships grounded in mutual respect and trust.

 MMA’s employees and members must not offer or accept any financial incentives or improper advantages, either directly or indirectly, for unfair or personal gain in business or financial matters. No individual within MMA is permitted to engage in behaviour that seeks to influence or appears to influence government officials, public authorities, or decision-makers by offering excessive, luxurious, or unusual gifts. Employees, members, and service providers within MMA must fully reflect the commitment to transparency and accountability. All MMA employees, including members of the Board of Directors, are required to confirm that they have read, understood, and implemented the principles of this Policy

4.1. Executive Board of MMA

The Executive Board oversees and reports on the implementation of transparency and accountability principles. Responsibilities of the Executive Board comprise following:

• Ensuring that financial and activity reports, along with reports from relevant staff responsible for administrative matters, are prepared and shared regularly,
• Submitting the annual financial reports by the requirements of the Law on Associations, 
• Ensuring contracts with third parties and employees are conducted transparently.
• Conducting fundraising processes in alignment with MMA’s principles, policies, and mission, 
• Identifying third parties to provide funding or capacity, preparing the necessary and fiscal documents, and applying for relevant funds or resources based on management decisions, 
• Submitting financial activity reports to third-party stakeholders providing resources and ensuring their audit, 
• Managing procurement, donations, and funding processes accurately and transparently, 
• Ensuring confidentiality agreements, contracts and the protection of personal data.
• Ensuring that management processes are open and accessible to stakeholders, 
• Providing feedback mechanisms and updating policy documents when necessary, 
• Implementing the recommendations provided by the Ethics Committee, initiating, managing, and concluding investigation processes, and invoking legal or judicial mechanisms if required. (In this regard, the procedures outlined in sections 4.4 and 5 of the Anti-Bribery and Corruption Policy apply.)

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4.2 Board of Control

• The Board of Control oversees MGD's financial processes, procurement activities, and the monitoring of donations and fund acquisitions. The Board of Control conducts at least one audit annually and presents the results to the Executive Board. The primary responsibilities of the Board of Control:
• Verifying the accuracy and transparency of the annual financial reports, 
• Monitoring the compliance of fund and donation usage with regulations,
• Conducting, filing, and archiving internal and external audit processes by legal regulations

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4.3. Employees

• All  MMA's employees are responsible for ensuring that MMA’s financial or other records are complete, valid, and accurate. All public announcements made by MMA must be fair, timely, and clear. Furthermore, the association’s records must be maintained in compliance with legal requirements and all MMA policies.
• All employees are responsible for safeguarding the association's assets, and for preventing the damage, theft, misuse, or waste of physical, intellectual, or financial assets. MMA’s non-public ideas, strategies, and business information must be securely protected.
• All employees are required to protect the personal information, email data, digital accounts, and project/program details of third parties and participants, in accordance with confidentiality agreements.
• Any violation of this Policy or other policy documents may result in serious consequences, including disciplinary actions up to termination of employment and potential legal or criminal penalties for both the association and individuals.
• At the end of each fiscal year, or within a month after the fiscal year has ended, employees and members sign the Transparency and Accountability Policy via the Declaration of Compliance with the Code of Conduct. (Annex-1)
  
  

4.3. Ethic Commission 

• The Ethics Committee upholds and promotes MMA’s ethical values and undertakes the necessary efforts for their development. The responsibilities of the Committee are:
• Reviewing notifications and conveying advisory decisions to the Executive Board, 
• Developing policies and procedures to prevent unethical behaviour, 
• Examining and resolving complaints and notifications related to unethical practices,
• When deemed necessary, employees and the Executive Board may seek guidance from the Ethics Committee on whether to accept or reject funds from a particular donor.

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   4.3.1. Selection and Structure of the Ethics Committee

   The Ethics Committee consists of one member each from the Executive Board and a member of the Control Board, provided there is no conflict of interest, a non-administrative member of the association, an employee, and an independent expert. The Committee meets at least once a year to review processes for compliance with ethical principles and make necessary updates.

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  5. Procurement Processes

  MMA ensures transparency and fair competition in all procurement processes. The procurement procedures aim to secure products and services that meet the association’s needs with the best price and quality. The procurement processes are carried out in coordination with the Executive Board by the relevant project or program coordinator and staff responsible for administrative activities. The procurement policy includes the following components: 

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• Bidding Process: Every bidding quote is obtained from at least two different suppliers. The quotes are evaluated based on price, quality, and delivery time. The reliability, experiences of previous performance and portfolio, and adherence to ethical values of the suppliers are also considered. 
• Consultancy Procurement: For services requiring expertise, the evaluation is based on price, experience, delivery time, relevant education, and professional experience in the areas.

Bidding and Tendering Processes: In cases MMA receives grants, the tender and quotation processes are conducted in compliance with the grant management and implementation guidelines and procedures of the donor organizations.

6. Funds and Capacity Building 

    MMA can receive funds and donations from resources that do not compromise its independence or mission. The use of funds and donations is based on the principle of transparency, and all processes are documented. The fund acquisition and donation acceptance policy contain the following elements

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   6.1 Funds and Grants 

   MMA can receive grants and/ or funds through international organizations, development agencies, consulates, foundations, and individual donations. MMA can collaborate with the private sector, public institutions, and international organizations and/or entities to develop its projects and programs. In the process of fund or/and grant acquisition:

• If a specific funding resource jeopardizes the association’s independence or poses a risk to the organization, the funding and/or grant will not be accepted by the association. 
• It is ensured that fundraising, resource mobilization, and fund allocation are ethical and do not compromise the organization’s commitments or values. 
• The contract process with the relevant donor organization is managed by administrative staff and the Executive Board.
• The decision to apply for funding and/org rant calls for all projects is made by the Executive Board.
• In adherence to confidentiality and contractual obligations, financial and administrative activities related to annually developed resources are reported both to the donor institution and through the DERBİS system under the General Directorate of Civil Society Relations.
• All processes related to the use of funds and/or grants are reported and shared with donor organizations and, partner organisations and affiliated entities.
•  Internal and external audit processes are implemented to prevent the misuse of funds.
• An inventory of all physical assets and equipment is maintained. This inventory is reviewed and verified at least once a year by the Executive Board.

6.2 Receiving Donations 

   MMA operates in accordance with the principles of transparency and accountability during the acceptance of donations. The following criteria are taken into account for the acceptance of donations:

• The purpose of the donation must align with MMA’s mission.
• The source of the donation must not originate from unethical activities. 
• Every donation is recorded with the approval of the Executive Board. MMA may conduct donation campaigns by participating in events, making announcements, or through the web. Such donation campaigns are initiated by a decision of the Executive Board and must comply with the Law on Fundraising No. 2860. 
• If a donation exceeds 20,000 TL from any individual or legal entity within a year, approval from the Executive Board is required.

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  7. Reporting and Auditing 

  MMA regularly reports financial and administrative processes. Annual reports are prepared, detailing how funds and donations are utilized, how projects are conducted, and how procurement processes are managed. Audits include the following stages: 

• Internal Audit: The Executive Board conducts internal audits to ensure that activities comply with legal regulations and internal policies. 
• External Audit: Independent auditors verify the accuracy and transparency of financial reports. 
• Feedback: Feedback from beneficiaries, donors, and other stakeholders is regularly reviewed to improve MMA's activities and projects.

  8. Updating the Policy

 This policy is periodically reviewed and updated under the oversight of the Executive Board. Revisions are made in response to emerging needs and feedback. All employees and stakeholders are notified of the updated policy and are required to continue fulfilling their obligations.

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  9. Related Policies

  This policy document is a response to MMA’s accountability and transparency obligations towards the communities it collaborates with. It will be implemented in line with MMA’s other related policy documents.

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Annex-1:
Statement of Compliance with the Code of Conduct

As an employee/member of MMA, I hereby declare that I have read and understood the Ethics, Transparency, and Accountability Policy and Code of Conduct, which apply to all my colleagues, including Executive Board members, third parties, and our stakeholders:

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• I commit to conducting business processes honestly, fairly, ethically, inclusively, and participatively. 
• I will adhere to MMA's principles and other policies. 
• I will not use MMA's assets or my position for personal gain. 
• I will not use any information or opportunity that could harm MMA's interests for personal benefit. 
• I will promptly and appropriately share any information related to decision-making or any critical information regarding MMA with my colleagues.
• I will not engage in or practice discrimination based on race, gender, religion, language, belief, sex, sexual orientation, ethnicity, age, or disability.
• I will avoid any positions that could create conflicts of interest between my personal interests and duties related to the association. 
• I will comply with all MMA policies by the highest ethical standards. 
• In the event of any suspicion, allegation, or notification of fraud or corruption, I accept the internal and external procedures and practices outlined in the policy documents.
• In performing my official and representative duties, I will act by applicable laws, rules, and regulations. 
• I will not accept illegal payments, gifts, or rewards from individuals I know or am associated with in my official capacity.
• Without the approval of the Executive Board, I will not enter any business relationships with suppliers, service providers, or partners for personal gain. 
• I will not use MMA’s digital and social media accounts for personal benefit or any purposes other than those intended. 
• I will comply with my job descriptions and terms of service as outlined in my employment contract and adhere to updated policy documents.
• I will not share confidential information and acknowledge that failure to comply with the terms of service may result in the termination of my employment. 
• I affirm annually that I have adhered to this policy and have not violated it.

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