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Whistleblower Mechanism

Marsa’s Whistleblower Policy

Marsa’s Whistleblower Policy was put in place to allow any individual, whether a member of Marsa or an external individual or beneficiary, to report fraud, corruption and or other integrity issues (see table below) regarding Marsa, Marsa employees, our implementing organizations and related service providers (and their employees).

Any individual may report cases of misconduct that they have witnessed or have certain knowledge of even if the misconduct did not personally affect them. Individuals may also refer to the Marsa Whistleblower Policy if they are personally affected but wish to stay anonymous.

Marsa encourages individuals to report any misconduct promptly so that the organization can tackle the underlying issue and reduce any associated risks. Any reported case of misconduct will be handled promptly by the relevant Integrity Officer.

Who Can File A Complaint?
Everyone is encouraged to report any complaints including Marsa employees, implementing organizations, beneficiaries, service providers, and the general public.

What Can Be Reported?

FraudAny intentional or deliberate act to deprive another of property or money by guile, deception, or other unfair means.
BriberyThe practise of offering something, usually money, to gain an illicit advantage.
CorruptionDishonest or unethical conduct by a person often for personal gain.
TheftThe unauthorized removal or taking of supplies, equipment, furniture, fixtures, products, cash, merchandise or other tangible property.
Financial MismanagementStatements or actions that encourage or result in false or intentionally misleading entries into accounts, audits or financial records.
DiscriminationStatements or actions based on age, race, color, national origin, sexual orientation, gender, disability or religion that affect employment, promotion or compensation decisions.
HarassmentPersistent and uninvited statements, behavior or actions that are degrading, offensive, humiliating or intimidating and create an unpleasant or hostile environment. This includes sexual harassment.
Retaliation or RetributionStatements or actions discharging, demoting, suspending, threatening, harassing or discriminating against an employee because of any lawful act taken by the employee to report a violation of law or policy, file a complaint, or assist with an investigation or proceeding.
BullyingThe use of force, threats, or coercion to abuse, intimidate, or aggressively dominate others. The behavior is often repeated and habitual.
Modern SlaveryForced labor, sometimes also referred to as labor trafficking,  is when a person is forced to work through physical threats, psychological coercion, abuse of the legal process, deception, or other coercive means.
Human TraffickingHuman trafficking involves recruitment, harboring or transporting people into a situation of exploitation through the use of violence, deception or coercion and forced to work against their will.

Marsa’s Integrity Officers

An integrity officer is an individual assigned by the Board to receive and handle complaints. Marsa currently has two assigned integrity officers an internal and an external officer. The internal and external integrity officers have experience in ethics and handling disputes regarding integrity.

• Internal Integrity Officer
Dr. Ayman Assi is the President of Marsa and the assigned internal integrity officer.
Informants can contact Dr. Assi or issue a complaint through:

• External Integrity Officer
If the informant prefers to submit the complaint to an external individual, they have the option to contact Marsa’s external integrity officer Professor Roland Tomb. Professor Tomb is an advisory board member of Marsa who holds a doctorate in Philosophy and Ethics.

Informants can contact Professor Tomb to issue a complaint via

Reporting Mechanisms

If any informant wishes to report their concerns can contact Marsa’s integrity officers. Informants have the choice to state their identity, which will be protected, or to remain anonymous. The integrity officer will facilitate steps that guarantee the anonymity of the individual.

A- Informal Complaints Mechanism
If the informant wishes to deal with the complaint informally, then they can contact Marsa’s internal integrity officer. The internal integrity officer will then:

  1. Give an opportunity to the alleged perpetrator to respond to the complaint
  2. Ensure that the alleged perpetrator understands the complaints mechanism
  3. Facilitate discussion between both parties to achieve an informal resolution which is acceptable to the complainant, or refer the matter to a designated mediator within the organization to resolve the matter
  4. Ensure that a confidential record is kept of what happens
  5. Follow up after the outcome of the complaints mechanism to ensure that the behavior has stopped
  6. Ensure that the above process is completed within [60] days of the complaint being made
  7. Ensure that retaliation against the complainant is expressly prohibited.

B- Formal Complaints Mechanism
If the informant wants to make a formal complaint or if the informal complaint mechanism has not led to a satisfactory outcome for the complainant, the formal complaint mechanism should be used to resolve the matter. The integrity officer who receives the complaint will:

  1. Conduct a thorough investigation into the complaint by interviewing the complainant and the alleged perpetrator separately and any other relevant third parties
  2. Deliver the results of the investigation to all parties involved and recommending a clear and practical process for resolution
  3. Follow up to ensure that the recommendations are implemented and that the complainant is satisfied with the outcome
  4. Keep a record of all actions taken
  5. Ensure that all records concerning the matter are kept confidential
  6. Ensure that the process is done as quickly as possible within [90] days of the complaint being made
  7. Marsa will allocate a budget of 3,000 USD to ensure all procedures of the mechanism are covered financially.

How To File A Complaint?
Please e-mail your complaint (or suggestion) to your Marsa contact person, copying in our Executive Director If you do not have or cannot use your contact at Marsa, or if you wish to make a general complaint, you can e-mail or

  • Please include the subject of the complaint and a detailed description in your e-mail. Otherwise, it will not be treated as a complaint.