This article is part of IIU's Integrity Champion Spotlight series, designed to highlight integrity best practices that GCF Direct Access Entities are developing and implementing. This series will showcase these best practices and provide some lessons learnt for other Direct Access Entities who may be interested in establishing similar systems.

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At the Environmental Investment Fund of Namibia (EIF), the team has a core question in mind when communicating their integrity policies: how can the messaging be as accessible as possible? 

This question has been top-of-mind in 2023, because EIF has published two updated integral documents – a Business Conduct and Code of Ethics Policy, which defines the code of conduct for anyone working with EIF, and a Project and Grant Management Manual, which provides a roadmap for guiding operations and requirements for project selection, monitoring and evaluation. 

To accompany these guidelines, EIF is implementing awareness-raising initiatives to better educate their stakeholders. These activities include internal information sessions, community visits, training for their Board of Directors and national radio broadcasts. 

Clearly communicating ethics and operational guidelines is critical for EIF, which was accredited as a Direct Access Entity in 2015 and now has four ongoing GCF projects totaling 39.1 million USD in concessional finance. These projects include FP023 and FP024, which focus on sustainable natural resource management and supporting resilient livelihoods, as well as two Simplified Approval Process projects (SAP001 and SAP006) on ecosystem management and food security.

New in the Business Conduct and Code of Ethics Policy is a section on the behavior of service providers that work with EIF. With this addition, EIF can help prevent the service providers from taking advantage of local communities. “We would want to see the obligations in this policy coming out more strongly in the service-level agreements that the service providers have with these beneficiary communities,” Carol-lee Pick, Legal Advisor and Compliance Officer at EIF, explained. 

The 2023 version of the Project and Grant Management Manual is a streamlined document that enables stakeholders to have a comprehensive list of relevant requirements for EIF operations and projects. The updating process started after it was reaccredited by GCF in 2021 and the organisation needed to include more detailed information about GCF projects. 

An important step for EIF was publishing these policies. But without a concerted effort to educate stakeholders about them, there could be little buy-in or adherence from stakeholders. 

To build awareness, EIF is implementing a toolbox of internal and external initiatives. Already, the Operations team hosts a monthly internal information session to share information on obligations to GCF projects and background on funding activity agreements. 

The EIF team is planning on hosting a similar series of sessions internally on the Business Conduct and Code of Ethics Policy. Part of the education initiatives on this policy will also include infographics, fact sheets, and posters that will be developed by the EIF team. Carol-lee got the idea for these creative materials from participating in the one-on-one clinic sessions held during the 2023 GCF Integrity Forum, which the Independent Integrity Unit hosted in September. 

Also during the Integrity Forum, which brought together 54 integrity professionals from 36 Direct Access Entities, there were interactive group sessions where participants could work together on analysing case studies and brainstorming integrity best practices. 

“The working group sessions were so helpful that when I came back, I integrated some of those things into the draft policies,” Carol-lee said. “It was really informative in moving them forward.” 

It has also been critical that EIF executive leadership take charge of advancing knowledge of and adherence to integrity policies. “Your leaders should be the ones that are running the process, because that then trickles down to the rest of the organisation,” Carol-lee explained. 

To emphasise this top-down commitment to establishing an integrity culture, EIF has developed a training session on integrity, compliance and governance for their new Board of Directors members so that they have the foundation on the organisation’s integrity policies. 

Externally, EIF has taken steps to advance awareness on integrity issues in the communities they work with. One of the challenges, Bernadette Shalumbu Shivute, Programming Manager at EIF, explained, is that there are 14 spoken languages in Namibia, making it difficult for this information to reach everyone. To address this, EIF has been in consultation with the national broadcast network to translate and communicate integrity messages to as much of the country as possible. 

Beyond the radio message, EIF conducts in-person fieldwork, sitting down with communities to convey relevant information directly to local leaders through staff translators. 

There have been many lessons learnt for Carol-lee and Bernadette over the course of developing these policies, but a focus on partnerships and collaboration stands out. “You don’t have to reinvent the wheel,” Carol-lee said. “Reaching out to others with shared experiences has helped to get us to this point of making the policies easier to understand.” 

To learn more about these policies or capacity building initiatives at EIF, please contact Carol-lee at [email protected].