Institutional & Donor Compliance Framework

52. Purpose and Applicability

This Institutional and Donor Compliance Framework establishes the governance, accountability, reporting, and ethical standards that Mentora Tanzania (operated by Evolucion Technologies Company Limited) adheres to in its engagements with international development partners, grant-making bodies, and institutional donors.

This framework is designed to meet the compliance expectations of organizations including, but not limited to:

• GIZ (Deutsche Gesellschaft für Internationale Zusammenarbeit)
• Mastercard Foundation
• Botnar Foundation
• USAID and affiliated bilateral agencies
• World Bank Group
• UNICEF and other UN entities
• Other bilateral and multilateral funders with governance and accountability requirements

53. Governance Structure

The Company operates under a governance structure that supports accountability and transparency:

• Board of Directors: Provides strategic oversight, fiduciary responsibility, and compliance governance.
• Chief Executive Officer (CEO): Responsible for overall organizational leadership and donor relationship management.
• Data Protection Officer (DPO): Oversees data protection compliance and reports to the Board on privacy posture.
• Chief Technology Officer (CTO): Responsible for platform security and technical compliance.
• Finance & Compliance Manager: Manages financial reporting, audit readiness, and regulatory compliance.

54. Financial Accountability and Reporting

The Company adheres to the following financial accountability standards:

• Maintaining accurate, complete, and timely financial records
• Segregation of donor funds from operational revenue
• Grant funds used exclusively for agreed-upon project activities
• Annual independent financial audits by a recognized audit firm
• Compliance with International Financial Reporting Standards (IFRS) or equivalent
• Quarterly financial reporting to donors as required by grant agreements
• Maintaining a minimum of seven (7) years of financial record retention

55. Donor Audit Rights

The Company grants donors and their authorized representatives the following audit rights:

• Right to conduct or commission financial and programmatic audits at reasonable notice
• Access to relevant financial records, project documentation, and performance data
• Right to conduct site visits to verify project implementation
• Right to interview staff and beneficiaries as part of evaluation processes
• All audit findings shall be addressed through documented corrective action plans

56. Anti-Corruption and Anti-Fraud Policy

The Company maintains a zero-tolerance policy toward corruption and fraud:

• No employee, contractor, or agent shall offer, give, solicit, or accept bribes or improper payments
• All employees receive annual anti-corruption training
• A confidential whistleblower mechanism is available for reporting concerns
• Allegations of fraud or corruption are investigated promptly and independently
• Confirmed violations result in disciplinary action, including termination and legal referral
• Compliance with the Tanzanian Prevention and Combating of Corruption Act

57. Ethical Standards and Code of Conduct

All personnel are bound by the Company's Code of Conduct, which includes:

• Commitment to integrity, honesty, and professionalism in all dealings
• Respect for human rights, dignity, and cultural diversity
• Non-discrimination on the basis of gender, ethnicity, religion, disability, or political affiliation
• Environmental responsibility and sustainability consciousness
• Conflict of interest disclosure and management
• Responsible use of organizational resources

58. Safeguarding and Child Protection

Given Mentora's work in education involving children and young people, the Company maintains rigorous safeguarding standards:

• All staff undergo safeguarding training before engaging with schools or students
• Background checks are conducted for personnel with access to children's data or direct contact with students
• A designated Safeguarding Officer oversees compliance with safeguarding policies
• Safeguarding concerns are reported through a confidential reporting mechanism
• The Company does not tolerate any form of abuse, exploitation, or harassment
• Compliance with the Tanzanian Children's Act and international safeguarding standards (e.g., Keeping Children Safe standards)

59. Environmental, Social, and Governance (ESG) Commitment

• Environmental: Commitment to minimizing environmental footprint through efficient cloud computing, reducing paper usage, and promoting digital-first operations.
• Social: Advancing educational equity, supporting teacher wellbeing, empowering underserved communities, and promoting gender equality in STEM education.
• Governance: Transparent decision-making, stakeholder accountability, ethical business practices, and compliance with all applicable laws and regulations.

60. Impact Measurement and Reporting

The Company is committed to evidence-based impact measurement:

• Baseline assessments are conducted before program implementation
• Key Performance Indicators (KPIs) are defined in collaboration with donors and partners
• Regular progress reports are provided in alignment with donor reporting schedules
• Independent evaluations may be commissioned as agreed with funding partners
• Disaggregated data (by gender, region, school type) is collected and reported where applicable
• Lessons learned are documented and shared with stakeholders

61. Sanctions Compliance

The Company does not knowingly engage with any individual, entity, or country subject to international sanctions imposed by the United Nations, European Union, United States (OFAC), or other relevant sanctions authorities. Sanctions compliance screening is conducted as part of due diligence for all significant partnerships and vendor engagements.

62. Donor-Specific Obligations

Where specific donors impose additional compliance requirements beyond this framework, the Company shall:

• Review and incorporate donor-specific requirements into project implementation plans
• Assign a dedicated compliance liaison for each major donor relationship
• Ensure all staff involved in donor-funded projects are trained on applicable requirements
• Maintain separate project documentation as required by individual grant agreements

63. Board Commitment Statement

Contact

For compliance and donor relations inquiries, contact: mentoratanzania@gmail.com.