hera has a zero-tolerance approach to any form of modern slavery. Modern slavery is a crime and a violation of fundamental human rights. Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour and human trafficking as per the EU Charter of Fundamental Rights Article 5 – Slavery / Forced Labour which corresponds to Article 4(1) and (2) of the European Court of Human Rights (ECHR).

Principles

1. Conflict of interest. We the undersigned will avoid any conflict – real or potential- between our personal interests and the interests of hera.

2. Misuse of official position and public resources. We will not seek to influence for private purposes any person or body by using our official position or offering them personal advantages. Likewise, we will not use public property, facilities, services, and financial resources for private purposes except when permission is lawfully given. Moreover, we will not use our official position to abuse people or sexually exploit them.

3. Respect for laws. We respect the laws of the countries in which we work.

4. Proper personal conduct. We will ensure that our private conduct does not compromise our role as hera consultant or employee.

5. Active and passive bribery. We will not give, solicit, or receive directly or indirectly any gift or other favour that may influence the exercise of our function, performance or duty or judgment. This does not include conventional hospitality or minor gifts.

6. Anti-corruption. In accordance with the principle of “zero tolerance”, we are obliged to report suspicion or evidence of corruption committed by colleagues or others.

7. Openness and transparency as a rule - confidentiality when required. We will strive to achieve maximum openness and transparency towards our clients. However, confidentiality will be applied when necessary to safeguard the rights of our partners, staff, and others.

8. Non-discrimination. In our work we do not discriminate in respect of gender, colour, religion, culture, education, social status, ethnic belonging or national origin or any other status.

9. Our commitment to the environment and sustainability is integral to our values and operations. We recognise the importance of protecting the environment and do no harm with our operations. Therefore, we are aiming to minimise our environmental impact and footprint and we ask to all our contracted consultants to pay attention to these aspects by adhering to this code of conduct.

10. Dissemination of the Code. We will make our Code known to our Professional partners.

11. Observance of the Code. We will respect the principles of the Code and will report any evidence or suspicion of breaches to the code. The responsible superiors will ensure the legal rights and due protection of the whistleblower and the accused before, during and after investigation. Any concern or issue can be raised with the hera safeguarding team (hera CEO and Director) using safeguarding@hera.eu.

    Commitments

    We are influential in health and development policy at local, national, regional, and global level.

    We contribute to building capacity of duty bearers to provide equitable access to health services.

    We listen to, integrate, and advocate the views and priorities of right holders in our work.

    We integrate local context and knowledge in our practice.

In all its assignments, hera will pay particular attention to avoiding any conflict of interest. hera partners, associates, contracted consultants and staff need to be independent, objective and impartial and must demonstrate personal and professional integrity.

hera undertakes to make every effort to comply with applicable laws and regulations related to Personal Data protection in countries where hera operates and to protect the confidentiality of personal data collected in line with the European Regulation EU General Data Protection Regulation (GDPR) 2016/679 of the European Parliament and of the Council of 27 April 2016.

The Data Protection and Information policy sets forth the basic principles by which hera processes the personal data of customers (clients and consultants), suppliers, business partners, employees and other individuals and indicates its responsibilities while processing personal data, and the security measures taken to protect this data.

This policy applies to hera partners, associates, employees and contracted consultants conducting business with the European Economic Area (EEA) or processing the personal data of data subjects within the EEA.

hera has a pro-active environmental policy in order to limit the environmental damage due to its activities, this is done by :

• acquiring better insight in the environmental actions of the company and the continued search for improvement of environmental actions.

• executing a policy of rational use of water, energy and raw materials in its office and encouraging employees, partners and associates to also do this in their home offices (e.g. use of 100% green energy for the office as well as saving light bulbs).

• offering information and education to partners, associates, consultants and employees of environmental problems (e.g. a yearly session on this topic is held during the hera’s Extraordinary General Assembly and a list of available training is included at the end of this policy).

• raising awareness for environmental problems and drawing attention to the reduction of the ecological footprint when organising consultancies.

• assessing, from an ecological viewpoint, each technical/financial proposal to be submitted by hera to a client (e.g., how to minimise the ecological footprint of the proposed action) according to the hera climate guidelines.

• compensating for our CO2 emissions, for all air travel, by investing in sustainable energy projects through the Climate Neutral Group, and,

• encouraging hera partners, associates, employees and contracted consultants, when travelling, to book accommodation through Staze, to further reduce our CO2 emissions.

hera is a signatory to the United Nations Global Compact, through which we reconfirm hera’s commitment to the ten principles of the Compact to human rights, labour, anti-corruption and the environment. In particular to the environment hera commits to the following principles: 7) businesses should support a precautionary approach to environmental challenges; 8) undertake initiatives to promote greater environmental responsibility; and 9) encourage the development and diffusion of environmentally friendly technologies.

Environmental system

In 2015 hera joined efforts with “ondernemers zonder grenzen” (Entrepreneurs without borders) to help offset air travel and support reforestation efforts in the Sahel. hera tries to prioritise work with small or medium enterprises and will at all levels of its work engage with local communities.

In addition:

• hera has downsized the office facilities and moved into a smaller co-working office building which uses energy from 100% green sources and has issued a CO2 neutrality certificate.

• hera aims for a paper free office. We work mostly online using Sharepoint and Teams as part of our Virtual Office and share documents as much as possible through these platforms or by e-mail instead of hard copies. E-mails and documents are only printed when necessary. If we do print, it is always done recto-verso on chlorine free paper. We also use chlorine free envelopes.

• hera makes optimal use of audio conferencing and uses VOIP calls Audio conferencing reduces the need for long-distance international travel and enables our counterparts to effectively communicate with hera consultants.

• In 2022, hera has embarked on a process to include the climate-health nexus more formally into our strategy and operations to minimize our negative environmental impact, create transparency on our carbon footprint, harness growing attention to the climate-health nexus, demonstrate authenticity and value-driven mindset and facilitate future compliance and improved accountability. As a result of this process, we are pursuing to obtain B-Corps certification and developed the hera Climate Guidelines.

Environmentally preferred products and practices in employee virtual offices.

hera strongly advises all contracted personnel, associates and shareholders to choose environmentally preferred products or services, which have a reduced effect on human health and the environment when compared to competing products or services that serve the same purpose.

Environmentally preferred purchasing considers both the cost and the environmental impacts of a product or service.

hera’s personnel, associates and shareholders, shall purchase and use materials, products and services which are fiscally responsible, reduce resource consumption and waste, promote opportunities to lesser advantaged segments of the community, perform adequately, and promote human health and well-being.

hera supports the purchase of recycled and environmentally preferred products and strongly recommends the following actions and behavior to its personnel, associates and shareholders also in their virtual offices:

• Office supplies/equipment: purchase products that perform and have the least damaging/most beneficial environmental impact, including new environmentally preferred products, reusable products, recycled content, and recycled products;

• When purchasing office furniture, opt for sustainable materials (durable, reusable or recyclable, including recyclable materials in their composition and made from resources of the area where the office activity will take place (local and natural materials: wood, cork, bamboo, etc.). Opt for ecolabels materials (B-Corporation, EU Ecolabel, Fairtrade, etc.) ;

• Try to choose office supplies marked with environmental signs and when purchasing something to minimise transportation (e.g. try to obtain products from local sources)

• Reduce water and energy consumption (e.g. monitor your heating, cooling and air quality; use low-consumption bulb lamps and take advantage of natural lighting; unplug at the end of the day; commute efficiently using public transport);

• Reduce printing and mail supplies, including paper products as much as possible, favoring digital sharing of documents. When printing is necessary implement sustainable printing practices: use recycled paper and print on both sides of the page. Moreover, if possible, choose environmentally friendly ink/toner options such as refillable printer cartridges;

• Choose products with minimal packaging (e.g. meal during lunch breaks);

• Try to always reuse existing products or materials in the product or service life cycle (e.g. before purchasing office material make sure that no other option is already available at the hera office). Purchase only products or services truly necessary.

Safe disposal of e-waste and other hazardous materials purchased for hera office and home offices

Many electronic devices contain hazardous chemicals. If they aren’t disposed of safely, those chemicals can pose a safety hazard to people, animals and the environment. In addition to contaminated soil, hazardous wastes can pollute the air and leach into water sources.

There are many ways to safely dispose of electronics. Here are a few options:

• Check with retailers: Some retailers will take back old electronics you purchased at their stores, especially if you purchase new items to replace the disposed ones;

• Donate to charities: If the product is in good condition, many charities, IT clubs, schools or facilities for elderly people accept electronics as donations;

• Use a disposal service if need be.

hera is committed to protect the wellbeing of all people who work directly and indirectly with and through our organisation.

This policy covers the safeguarding of safety of people who come into contact with hera. The purpose of this policy is to protect people, particularly children and at risk adults, from any harm that may be caused due to their contact with hera. This includes harm arising from contact with hera’s internal staff or external consultants. This policy is based on the Belgian law of 4 August 1996 concerning the well-being of employees while executing their work; Directive 2011/93/EU of the European Parliament and the Council of 13 December 2011 on combating the sexual abuse and sexual exploitation of children and child pornography; and Directive 2002/73/EC of the European Parliament and of the Council of 23 September 2002 amending Council Directive 76/207/EEC on the implementation of the principle of equal treatment for men and women as regards access to employment, vocational training and promotion, and working conditions.

This policy covers all personnel of hera, whether employed permanently or as a consultant or contractor, associated personnel as well as staff and associated personnel from organisations employed to deliver services on our behalf.

Scope and Statement

hera believes that everyone who comes into contact with hera, regardless of age, gender identity, disability, sexual orientation or ethnicity has the right to be protected from all forms of harm, abuse, neglect and exploitation.

hera will never tolerate abuse and exploitation by staff or associated personnel or organisations employed to deliver services on our behalf.

This policy addresses the following areas of safeguarding:

i. child safeguarding,

ii. adult safeguarding; and,

iii. protection from sexual exploitation and abuse.

Prevention at organisational level (hera)

• hera will ensure that all staff have access to and are familiar with this safeguarding policy.

• hera has appointed a safeguarding team, consisting of a designated safeguard officer, the confidence officer and a senior manager. They can be contacted individually or via e-mail at safeguarding@hera.eu.

• hera has also appointed a confidence officer (see hera’s whistleblowing and anti-fraud policy).

• In all its assignments, hera will prioritise the protection of children and people from any risk of harm that may arise when working with or through hera. This includes data protection of individuals coming in contact with hera (see hera’s data protection and information security policy).

• hera will follow its rigorous recruitment policy when recruiting and managing staff (see hera’s recruitment policy).

• hera will at all time welcome information about safeguarding concerns being brought to its attention (see hera’s whistleblowing, anti-fraud and corruption policy).

Prevention by staff and associated personnel

i. Child safeguarding

Staff and associated personnel must not:

• Engage in sexual activity with anyone under the age of 18

• Sexually abuse or exploit children

• Subject a child to physical, emotional or psychological abuse, or neglect

• Engage in any commercially exploitative activities with children including child labour or trafficking

ii. Adult safeguarding

Staff and associated personnel must not:

• Sexually abuse or exploit at risk adults

• Subject an at risk adult to physical, emotional or psychological abuse, or neglect

iii. Protection from sexual exploitation and abuse

Staff and associated personnel must not:

• Exchange money, employment, goods or services for sexual activity. This includes any exchange of assistance that is due to beneficiaries of assistance

• Engage in any sexual relationships with beneficiaries of assistance, since they are based on inherently unequal power dynamics

Additionally, hera staff and associated personnel are obliged to:

• Contribute to creating and maintaining an environment that prevents safeguarding violations and promotes the implementation of this safeguarding policy

• Report any concerns or suspicions regarding safeguarding violations by a hera employee or associated personnel or by staff or associated personnel from organisations employed to deliver services on our behalf

How to report a safeguarding concern

A safeguarding concern is any allegation or suspicion that someone associated with hera’s work has caused or may be at risk of harm or abuse.

hera operates a low-level concern approach which means that even minor concerns or suspicions of harm must be reported.

All safeguarding concerns must be reported to the hera Safeguarding Team. This can be done by e-mail to safeguarding@hera.eu. The Safeguarding Team safeguarding@hera.eu will discuss the concern with the person reporting the concern and decide what further action is required.

Response and Confidentiality

• If requested, the identity of the whistle-blower will be kept confidential, regardless to whom the (suspicion) of misconduct has been reported – unless the law requires hera to break the confidentiality.

• Whether the identity of the whistle-blower is known or kept anonymous, victimisation, reprisals or other forms of harassment will in no way be tolerated and appropriate measures will be taken against it.

• hera aims to deal with all disclosed concerns in a fitting and timely manner. All matters raised will be acknowledged and dealt with as soon as possible.

• To ensure awareness, whistleblowing is mentioned in the Code of Conduct which in turn is an essential part of each contract hera signs with a consultant or sub-contractor. The Code stresses that hera will ensure the legal rights and due protection of the whistle-blower.

Next to the accessible documented policies and practices, every hera contract, with office staff, external consultants and partners, includes our Code of Conduct. This Code of Conduct describes our key principles and states that confidentiality will be applied when necessary to safeguard the rights of our partners, staff and others.

As a key principle, hera is committed to upholding the highest standard of honesty, integrity, openness and ethical conduct. Our Whistleblowing and Anti-Fraud and Corruption Policy has been established to protect these values and offer a guideline to ensure consistent and fair reporting, investigation and disclosure of fraud and other malpractices.

The Whistleblowing and Anti-Fraud and Corruption Policy builds upon hera’s Code of Conduct. The Code of Conduct is a fundamental document for all parties that work for or with hera. All employees, consultants, partners, associates and subcontractors sign the Code, should respect its principles and are encouraged to report any evidence or suspicion of breaches to the Code by blowing the whistle.

The responsible superiors (hera’s board of directors) will ensure the legal rights and due protection of the whistle-blower and the accused before, during and after the investigation.

Whistleblowing

• hera at all times welcomes information being brought to the attention of hera’s board of directors and asks its employees and partners to actively come forward if they suspect, or have proof of, violations of hera’s Code of Conduct. Contact information of hera’s management team is publicly available on http://www.hera.eu/en/about/our-people/hera-board-ofdirectors/.

• hera recognises that it can be difficult to report suspected malpractice and fraud. The organisation fully encourages and enables employees, consultants, partners, subcontractors and other parties involved to speak up.

• Whistle-blowers are encouraged to contact hera’s safeguarding team, consisting of the hera Director and the hera CEO. They can be contacted via e-mail at safeguarding@hera.eu.

• Both the safeguarding team and hera’s board of directors will protect the safety and privacy of the person raising concerns about wrongdoing.

• If requested, the identity of the whistle-blower will be kept confidential, regardless to whom the (suspicion) of misconduct has been reported – unless the law requires hera to break the confidentiality.

• Whether the identity of the whistle-blower is known or kept anonymous, victimisation, reprisals or other forms of harassment will in no way be tolerated and appropriate measures will be taken against it.

• hera aims to deal with all disclosed concerns in a fitting and timely manner. All matters raised will be acknowledged and dealt with as soon as possible.

• The organisation fully recognises the importance of whistleblowing for the whole of the company, including all employees and partners.

• hera therefore aims to fully embed its whistleblowing policy and process throughout the organisation. All parties working with and for hera are made aware of the possibility to blow the whistle in cases of misconduct, and are fully encouraged to do so.

• To ensure awareness, whistleblowing is mentioned in the Code of Conduct which in turn is an essential part of each contract hera signs with a consultant or sub-contractor. The Code stresses that hera will ensure the legal rights and due protection of the whistle-blower.

Anti-Fraud and Corruption

• Following the Code of Conduct, hera will not tolerate the direct or indirect giving, soliciting or receiving of gifts or other favours that may influence the exercise of our function, performance or duty or judgment. This does not include conventional hospitality or minor gifts. Active and passive bribery will not and cannot be accepted.

• hera demands openness and transparency as a rule, and confidentiality when required; respect for the laws of the countries in which we work; anti-corruption and non-discrimination at all times; avoidance of conflicts of interest; and zero-tolerance for any misuse of official position or public resources and active or passive bribery.

• In accordance with the principle of “zero tolerance”, hera is obliged to report suspicion or evidence of corruption committed by colleagues or others to its Board of Directors who will decide on the appropriate action to be taken.

• Proactively, hera will do due diligence checks and regular performance feedback on all partners and closely monitor all work.

• As a reactive measure, hera can decide to suspend payment, terminate the contract with the contracted person, staff, partner or associate or even recover funds.

• hera’s anti-fraud and corruption policy is adopted across the whole organisation and applies evenly to all employees, consultants, partners, associates and sub-contractors.

• Any suspicions or allegations of fraud and/or corruption are to be brought to the attention of hera’s board of directors. The whistleblowing policy will be followed and respected at all times.

• When working on FCDO funded projects, all parties involved must report all suspicions or allegations of aid diversion, fraud, money laundering or counter terrorism finance to the Counter Fraud and Whistleblowing Unit (CFWU) at reportingconcerns@fcdo.gov.uk or on +44 (0)1355 843747.This contact information will be provided and highlighted in all relevant (sub) contracts.

⇒ All employees are made aware of the Whistleblowing and Anti-Fraud and Corruption Policy.