Report to the IIU


GCF defines wrongdoing as conduct that violates GCF policies or which involves significant risk to the GCF because it is harmful to its interests, reputation, operations, or governance. Wrongdoing includes but is not limited to misconduct, conflicts of interest, and prohibited practices.​

Prohibited practices

The promise, offering, giving, receiving, or soliciting, directly or indirectly, anything of value (including but not limited to gifts, gratuities, entertainments, favours, invitations, and benefits of any kind) or any undue advantage, or any act or omission that involves the abuse of authority or functions, for the purpose of influencing or to causing to influence improperly the actions of another party, or for the purpose of obtaining an undue advantage for oneself or for another party.

Any act or omission, including misrepresentation or concealing material fact, that knowingly or recklessly misleads, or attempts to mislead, a party for the purpose of obtaining a financial or other undue advantage for oneself or for a third party.

The impairing or harming, or threatening to impair or harm, directly or indirectly, any party or the property of the party for the purpose of improperly influencing the actions of a party.

An arrangement between two or more parties designed to achieve an improper purpose, including for the purpose of improperly influencing the actions of another party.

(1) Deliberately destroying, falsifying, altering, concealing, or unreasonably withholding evidence or other requested information, documents, or records, which are material to a Fund investigation; (2) making false statements to investigators in order to materially impede a Fund investigation; (3) threatening, harassing, or intimidating any party to prevent it from disclosing its knowledge of matters relevant to a Fund investigation or from pursuing a Fund investigation; or (4) materially impeding the Fund’s contractual rights of audit or access to information.

Theft, misappropriation, waste, or improper use of property or assets related to a Fund‐related Activity, either committed intentionally or through reckless disregard.

(a) The conversion or transfer of property, knowing that such property is derived from a crime, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of a crime to evade the legal consequences of his or her actions; (b) the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of or rights with respect to property, knowing such property is derived from crime; or (c) the acquisition, possession, or use of property knowing at the time of receipt such property was derived from a criminal offence.

Defined as the commission of any offence as set out in Article 2 of the International Convention for the Suppression of the Financing of Terrorism.

Any detrimental act, direct or indirect, recommended, threatened, or taken against a whistleblower or witness (as such terms are defined in the relevant GCF policy), or person associated with a whistleblower or witness, because of his or her report of suspected wrongdoing or cooperation with a Fund investigation by the whistleblower or witness.

Sexual exploitation, sexual abuse, & sexual harassment

Any actual or attempted abuse of a position of vulnerability, differential power, or trust, for sexual purposes, including, but not limited to, threatening or profiting monetarily, socially, or politically from the sexual exploitation of another.

The actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions.

Any unwelcome sexual advance, request for sexual favour, or other verbal, non-verbal, or physical conduct of a sexual nature, that interferes with work, is made a condition of employment, or creates an intimidating, hostile, or offensive environment in connection with a Fund-related activity, and, for the avoidance of doubt, Sexual Harassment may occur between or amongst persons of different sexes or genders or of the same sex or gender, and may be initiated by any gender or sex.

An arrangement between two or more parties designed to achieve an improper purpose, including for the purpose of improperly influencing the actions of another party.

Conflict of interest

Conflict of Interest is any situation in which a party or any of its staff involved in the relevant decision-making process has interests that could, or could be perceived to, improperly influence the performance of official duties or responsibilities, contractual obligations, or compliance with applicable laws and regulations.


Harassment is any unwelcome verbal or physical behaviour that unreasonably interferes with work or creates an intimidating, hostile, or offensive work environment.