Our Policies

1. Purpose

This policy establishes measures for preventing and responding to abuse, exploitation, harassment, neglect and other forms of harm arising from the organization's activities or personnel.

2. Scope

• Employees.
• Consultants and contractors.
• Volunteers and interns.
• Researchers and study personnel.
• Partners and representatives acting on behalf of the organization.
• Other persons participating in organizational activities where applicable.

3. Safeguarding Principles

• Treat every person with dignity and respect.
• Take reasonable steps to prevent abuse, exploitation, neglect and harassment.
• Give particular consideration to children, vulnerable adults, patients and research participants.
• Take safeguarding concerns seriously and respond promptly.
• Protect confidentiality while ensuring appropriate action is taken.
• Maintain zero tolerance for sexual exploitation and abuse.
• Protect persons reporting genuine safeguarding concerns from retaliation.

4. Prohibited Conduct

• Physical, sexual, emotional or verbal abuse.
• Sexual exploitation or harassment of patients, research participants, employees, community members or beneficiaries.
• Exploitation of a position of authority, trust or vulnerability for personal or sexual benefit.
• Inappropriate sexual conduct with children.
• Neglect or deliberate exposure of vulnerable persons to avoidable harm.
• Bullying, threatening, intimidating, humiliating or discriminatory conduct.
• Exchange of money, employment opportunities, organizational assistance, goods, services or other benefits for sexual activity or sexual favours.
• Ignoring, concealing or deliberately failing to report serious safeguarding concerns.

5. Responsibilities of Employees

All employees and representatives must familiarize themselves with this policy, maintain appropriate professional boundaries, treat individuals respectfully, take reasonable steps to prevent harm, promptly report suspected violations, cooperate with investigations, and maintain appropriate confidentiality. Managers and supervisors have an additional responsibility to promote a safe environment and ensure concerns are handled appropriately.

6. Reporting Safeguarding Concerns

Any person who witnesses, suspects, or receives information about abuse, exploitation, harassment, neglect, or other safeguarding concerns should report the matter promptly to the Immediate Supervisor, Human Resources/Administration, Designated Safeguarding Officer, Executive Director/Director, or an independent/Board contact where senior management is implicated. Where there is an immediate threat to someone's safety, protecting the affected person should be prioritized and appropriate competent authorities contacted where necessary.

7. Responding to a Disclosure

• Listen respectfully and take the concern seriously.
• Avoid blaming or judging the person.
• Do not promise absolute confidentiality.
• Record relevant information accurately.
• Report the concern promptly through the appropriate safeguarding channel.
• Do not conduct your own investigation unless formally authorized.

8. Confidentiality

Safeguarding information will be handled sensitively and shared only with persons who need the information for safeguarding, investigation, management or legal purposes. The privacy and dignity of affected persons will be respected.

9. Investigation and Response

Safeguarding allegations will be assessed promptly and handled fairly. The organization may conduct or commission an investigation, take immediate protective measures, temporarily adjust duties or access, take disciplinary action where misconduct is established, refer matters to relevant authorities or oversight bodies where required, and facilitate appropriate support for affected persons.

10. Recruitment and Prevention

Where appropriate to the role, safeguarding considerations will be incorporated into recruitment, induction, training, supervision and performance management. Personnel working directly with children, vulnerable persons, patients or research participants may be subject to additional screening and safeguarding requirements in accordance with applicable law and organizational procedures.

11. Protection from Retaliation

No person should be subjected to intimidation, harassment, discrimination or other retaliation for raising a genuine safeguarding concern in good faith or cooperating with an investigation.

12. Breaches of This Policy

Any employee or representative who breaches this policy may be subject to disciplinary action, including termination of employment or engagement where appropriate. Serious cases may also be reported to relevant authorities.

13. Training and Awareness

The organization will promote awareness of safeguarding responsibilities and provide appropriate training to personnel based on their roles and level of contact with potentially vulnerable persons.

14. Policy Review

This policy will be reviewed periodically and updated to reflect changes in legislation, organizational operations, donor requirements, research requirements and safeguarding best practices.

1. Policy Statement

• It is our policy to conduct all our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate, implementing and enforcing effective systems to counter bribery.
• We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. We remain bound by national laws.
• Bribery and corruption are prohibited in any transactions undertaken by TROPGAN, whether as donor or recipient of the gift.
• This policy applies to all employees, who will be contractually bound by it, and relevant Associated Third Parties, and shall be communicated to them at the outset of the business relationship and as appropriate thereafter.

2. Definitions

"Agent": Any individual acting as an agent, paid by the company, acting on the company's behalf in negotiating with third parties.

"Bribery" / "Corruption": Bribery occurs when one person offers, pays, seeks or accepts a payment, gift, favour, or a financial or other advantage from another to influence a business outcome improperly, to induce or reward improper conduct, or to gain any commercial, contractual, regulatory or personal advantage. It can be direct or indirect through third parties.

"Conflict of Interest": Occurs when an individual or organization is involved in multiple interests, one of which could possibly corrupt, or be perceived to corrupt, the motivation for an act in another.

"Donation": A voluntary contribution in the form of monetary or non-monetary gifts to a fund or cause for which no return service or payment is expected or made. Contributions to industry associations, or fines for memberships in organizations that serve business interests, are not necessarily considered donations.

"Employee": For this policy, this includes all individuals working at all levels and grades, including senior managers, scientists, directors, nurses, doctors, general workers, interns, volunteers, trainees and any other person associated with us.

3. Golden Rules

• No monetary advantage, gift, favour, entertainment, hospitality or other benefit shall be offered, promised, given, requested or accepted by or on behalf of TROPGAN where it could reasonably be perceived as intended to influence an improper decision or secure an improper advantage.
• Any monetary advantage, gift, favour, entertainment, hospitality or other benefit that could cause embarrassment to TROPGAN, its employees or associated parties if publicly disclosed shall not be offered or accepted.
• Where there is uncertainty regarding the appropriateness of any gift, benefit, hospitality or other advantage, guidance shall be sought from management before it is offered or accepted.
• Any situation that cannot be openly and satisfactorily explained to management or an independent party shall be regarded as a warning sign and referred to management for appropriate guidance or action.

1. Purpose

The purpose of this policy is to ensure that all employees, management and stakeholders act in the best interests of the organization and avoid situations where personal interests may conflict with official duties.

2. Scope

This policy applies to all employees, directors, board members, consultants and any individuals acting on behalf of the organization.

3. Definition of Conflict of Interest

A conflict of interest occurs when an individual's personal, financial or other interests interfere, or appear to interfere, with their ability to perform their duties objectively and in the best interest of the organization.

4. Examples of Conflict of Interest

• Hiring, supervising or influencing decisions involving relatives or close friends.
• Having a financial interest in a company that does business with the organization.
• Accepting gifts, favors or benefits from clients, suppliers or partners.
• Engaging in outside employment or business that competes with the organization.
• Using organizational resources for personal gain.
• Changing supplier for personal benefit rather than organizational interest.

5. Disclosure Requirements

All individuals covered by this policy must:

• Disclose any actual, potential or perceived conflict of interest.
• Complete and sign a Conflict-of-Interest Declaration Form annually or as required.
• Immediately report any new conflict that arises.

6. Management of Conflicts

Once a conflict is disclosed, the organization will review the situation objectively. Appropriate action will be taken, which may include:

• Removing the individual from decision-making processes.
• Reassigning duties.
• Approving the activity with conditions.
• Prohibiting the conflicting activity.
• Changing supplier.

7. Confidentiality

All disclosures will be treated with confidentiality and handled in a fair and transparent manner.

8. Non-Compliance

Failure to disclose a conflict of interest or violation of this policy may result in disciplinary action, including termination of employment or contract.

9. Review of Policy

This policy shall be reviewed periodically to ensure it remains relevant and effective.

10. Declaration

All employees and relevant stakeholders are required to acknowledge that they have read, understood and agree to comply with this policy.

1. Introduction

This Gender Equality Plan (GEP) establishes the organization's commitment to creating a fair, respectful and inclusive working environment free from discrimination, harassment and bias. This plan aligns with international research and donor expectations and supports equitable participation in health research, leadership, employment, training and decision-making.

2. Objectives

• Promote equal opportunities for all employees regardless of gender.
• Ensure fair recruitment, promotion, training and remuneration practices.
• Encourage balanced participation of women and men in leadership and research activities.
• Prevent gender-based discrimination, harassment and victimization.
• Promote work-life balance and staff wellbeing.
• Integrate gender considerations into research and organizational practices.
• Build awareness on gender equality and unconscious bias among staff.

3. Scope

This policy applies to:

• All employees of TROPGAN Ltd.
• Consultants and temporary staff.
• Researchers and research assistants.
• Students and interns.
• Volunteers.
• Collaborators operating within TROPGAN projects and facilities.

4. Key Commitments

4.1 Equal Opportunity and Non-Discrimination. TROPGAN Ltd shall provide equal employment and advancement opportunities to all individuals based on merit, qualifications and competence, without discrimination based on gender, marital status, pregnancy or maternity, disability, age, ethnicity, religion or social background.

4.2 Recruitment and Career Progression. The organization shall use fair and transparent recruitment procedures, encourage applications from qualified women and men equally, ensure selection panels make objective decisions based on qualifications and experience, promote equal access to promotions, leadership opportunities and professional development, and ensure equal pay for the same job, irrespective of gender.

4.3 Work-Life Balance. TROPGAN Ltd recognizes the importance of work-life balance and shall support maternity leave in accordance with Zambian labour laws, paternity and compassionate leave where applicable, flexible arrangements where operationally feasible, and a respectful and supportive workplace environment.

4.4 Prevention of Harassment and Gender-Based Violence. The organization maintains zero tolerance toward sexual harassment, workplace bullying, gender-based violence, intimidation or discriminatory conduct. All complaints shall be handled confidentially, fairly and promptly in accordance with organizational disciplinary procedures.

4.5 Gender Balance in Leadership and Research. TROPGAN Ltd will strive to promote balanced participation in management and leadership roles, encourage participation of women in scientific and technical roles, and ensure fair representation in trainings, workshops, conferences and study opportunities.

4.6 Gender Considerations in Research. Where applicable, research activities shall consider gender dimensions in study design and implementation, promote equitable participant recruitment, and ensure respectful treatment of all study participants.

5. Implementation Measures

• Publication and management commitment — this Gender Equality Plan shall be approved and signed by top management and made available internally to staff.
• Dedicated responsibility — the Human Resources and Administration Department shall coordinate implementation and monitoring of this plan.
• Data collection and monitoring — TROPGAN Ltd shall maintain gender-disaggregated staff data where feasible, including staffing composition, leadership positions and training participation. Annual reviews may be conducted to assess progress.
• Training and awareness — the organization shall periodically conduct awareness sessions on gender equality, workplace respect, prevention of harassment and discrimination, and unconscious bias.

6. Reporting and Review

This Gender Equality Plan shall be reviewed periodically to ensure continued relevance and effectiveness. Staff may provide recommendations for improvement through management structures.

1. Purpose

This policy provides a safe and confidential mechanism for employees and other persons associated with the organization to report suspected wrongdoing, misconduct, unethical behavior or illegal activities without fear of retaliation. The organization is committed to integrity, accountability, transparency and ethical conduct.

2. Scope

This policy applies to all employees, consultants, volunteers, interns, contractors and other persons working with or on behalf of the organization.

3. Matters That May Be Reported

• Fraud, theft, bribery or corruption.
• Misuse or misappropriation of organizational or donor funds.
• Falsification of financial, research, employment or other organizational records.
• Serious breaches of organizational policies or procedures.
• Abuse of authority or position.
• Harassment, discrimination, exploitation or other serious misconduct.
• Conduct that places the health or safety of employees, research participants, patients or members of the public at risk.
• Deliberate concealment of wrongdoing.
• Retaliation against a person who has raised a genuine concern.

Routine individual employment grievances should normally be handled through the organization's grievance procedures unless they involve serious misconduct or matters of wider organizational concern.

4. Reporting a Concern

A whistleblowing concern may be reported to the Immediate Supervisor, Human Resources/Administration, Executive Director/Director, Designated Whistleblowing Officer, or an independent/Board contact where the concern involves senior management. Reports may be made verbally or in writing. Where possible, the reporter should provide dates, persons involved, witnesses, supporting documents and a clear description of the suspected wrongdoing.

5. Confidentiality and Anonymous Reporting

All reports will be handled as confidentially as reasonably possible. The identity of a whistleblower will not be disclosed unnecessarily and will only be shared where required for proper investigation or legal compliance. Anonymous reports may be accepted, provided sufficient information is available to assess the concern.

6. Protection Against Retaliation

The organization prohibits retaliation against any person who raises a genuine concern in good faith. No employee should suffer dismissal, demotion, intimidation, harassment, discrimination, threats, loss of employment benefits or other unfair treatment because they reported a genuine concern or participated in an investigation. Retaliation may result in disciplinary action.

7. Investigation

All credible concerns will be reviewed promptly and objectively. Depending on the nature of the allegation, an appropriate internal or independent person or committee may be appointed to investigate. Persons implicated in a complaint should not control or improperly influence the investigation. Where appropriate or legally required, matters may be referred to relevant competent authorities.

8. False or Malicious Reports

Employees will not be penalized for genuine concerns that ultimately prove to be incorrect. However, deliberately making a false or malicious allegation, fabricating evidence, or knowingly providing false information may result in disciplinary action.

9. Records and Confidentiality

Appropriate records of reports, investigations, findings and actions taken will be maintained securely, with access limited to authorized persons.

10. Policy Review

This policy will be reviewed periodically and updated where necessary to reflect changes in legislation, organizational requirements, donor requirements and good practice.