Integrity Policy and Code of Conduct

This Policy and Code of Conduct is developed for all of Tana’s staff and sub-consultants and will encompass all our operations.

The Code is monitored by Tana’s management and any concern or suspicion of violation of the Code should be reported to them.

The overall principles in the Code are based on the UN Global Compact (UNGC) and the Association of Danish Management Consulting Firms (ADMCF). The Code is also aligned with Tana’s Business Integrity Management System (BIMS) and meets the recommendations of OECD.

Permanent staff are trained in the Code, and partners are made aware of the code, which is included as part of their contract.

General principles

Whoever we may deal with, and wherever we may operate, we are committed to doing so lawfully, ethically and with integrity. We acknowledge the principles in the UNGC, which are reflected below.

Human Rights

We support and respect the protection of human rights, and in our work, we will pay special attention to the rights of vulnerable groups, including women, children, indigenous peoples and migrants. We commit to not being knowingly complicit to any abuse of human rights in our work and will take appropriate steps to ensure that this is the case.

Labour conditions

We commit to upholding a safe and healthy working environment for our staff and partners. We will not permit any form of forced and/or child labour in relation to our work, and we will avoid any discriminatory practices in our recruitment processes. We will promote respect for diversity and ensure a harassment-free work environment. We will not tolerate any workplace violence, intimidation, abuse of power, or bullying.

Environment

We will promote environmental responsibility in our work, when relevant, and consider our environmental footprint when travelling in connection with our work. This implies that we will aim at taking the most direct route and avoid unnecessary travel activities.

Anti-Corruption

As part of our commitment, all forms of bribery and corruption are unacceptable and will not be tolerated. We must not, and we must ensure that any third party acting on our behalf does not, act corruptly in our dealings with any other person in relation to our services.

We will not in our services, nor in the procurement process, accept or offer any payment, consideration or benefit of any kind, which constitutes fraud, illegal or corrupt practices, neither directly or indirectly as an inducement or reward in relation to tendering, award or execution of contracts.

We will inform our counterparts of any potential conflict of interest, and we will not offer any gifts, meals or entertainment of an excessive value to clients or partners.

Code of Professional Conduct

As a fully-fledged member of the Association of Danish Management Consulting Firms (ADMCF) we abide by ADMCF’s “Code of Professional Conduct”.

The following principles are applicable for the members who ascribe to the Code of Professional Conduct. We:

• Only accept assignments that we have the skills and knowledge to perform.
• Will carry out the assignment effectively.
• Will draw up a written agreement for any assignment and ensure current evaluation with the client of their mutual expectations.
• Will work loyally in all dealings with the client.
• Will maintain a professional and proper approach towards the client’s potential or current employees and customers.
• Will treat client information as confidential.

Tana’s Business Integrity Management System (BIMS)

BIMS is implemented in Tana-EHG through the following management principles:

• The management of Tana-EHG signs all contracts with clients after having secured that the contracts are in accordance with legal, integrity and code of conduct requirements.
• For each assignment a project manager is appointed, who is responsible for ensuring that the assignment is carried out in accordance with the values and code of conduct of Tana-EHG.
• All contracts with sub-contractors must include a paragraph which reads as follows: “The sub-consultant is obliged to act in accordance with Tana-EHG’s Integrity Policy and Code of Conduct. Thus, no offer, payment, consideration, or benefit of any kind, which constitutes illegal or corrupt practices, shall be made, either directly or indirectly, as an inducement or reward in relation to the tendering, the award of contract, or the execution of the contract. Within the framework of the agreement Tana-EHG reserves the right to audit relevant business procedures including financial transactions and related documents. Tana-EHG has the right to terminate this agreement with immediate effect if the sub-consultant violates the said policy”.
• All outputs of assignments are quality assured by the project manager and all major final outputs are in addition quality assured by the management (Director, Senior Consultant and/or Business Manager) of Tana-EHG or by an independent Quality Assurance manager appointed by the management.
• All permanent staff are trained in Tana-EHG’s BIMS and all subcontractors and other short-term consultants working for Tana-EHG are informed in writing about the BIMS.

Tana-EHG embraces and complies with the international convention on human rights when carrying out business conduct, with special attention to vulnerable groups, who may often be the subject of images we use in any deliverables. We align our values to the principles of respect for others, human dignity, personal autonomy, and privacy, as stated in our Ethical Guidelines and Research Ethics. We aim to apply these standards to our reporting and work with clients as well as external consultants in our endeavours.

Please follow the link to find our guidelines

Privacy Policy & Terms of Use

Tana-EHG is committed to protecting the privacy of all our individual partners and colleagues. The information we provide in this document is designed to help you understand how we use your information and the choices you have for protecting it.

Personal Data

a) Personal data that is collected

• When submitting your CV, you are voluntarily sharing personally identifiable information such as name, address, telephone numbers, email addresses, skype ID, Facebook ID, preferences for short or long term missions, availability, full curriculum vitae, contact history.
• Individuals working in partner organisations or with clients share personally identifiable information such as name, function, telephone numbers and email address, contact history.
• Consultants and for Individuals working in organisations, share financial details (incl. VAT) when financial transactions occur.

b) Purpose of use of the Personal data

Consultants share data with Tana with the purpose of being contracted on Tana’s assignments and data on consultants are solely processed with the purpose of finding consultants employment opportunities on our contracts. Submitting your CV, via Tana’s website or via personal email contact, leads to the creation of a profile in our CV-Database which will contain the information submitted by you. The data about Consultants can be made available to the organisations that Tana collaborates with, including organisations based outside the European Economic Area (EEA), as part of preparing proposals. Is your profile found to be qualified and suitable as part of a consultant team, your data will be shared with external clients only on proposals in which you have agreed to participate.

Financial details are not shared, but are only used by Tana admin staff. Tana is not responsible for the privacy policies or practices of clients and partners to which we share Consultants CVs as part of proposals or contracting.

Data about individuals working in organisations can be made available to the organisations and Tana’s Consultants, can contact them for cooperation opportunities, with the sole purpose of ensuring efficient contract management and communication.

Any financial data is only stored and processed for the purpose of performing financial transactions between Tana-EHG and the client/consultants, or respecting Danish legal obligations. Tana does not provide any Personal data to third parties except if such disclosure is necessary in order to protect legitimate interests of Tana, its clients, or if it is required or permitted by law.

c) Duration the Personal Data is kept

Tana does not keep Personal data for longer than necessary for the purposes for which it was collected and processed.

d) Confidentiality of the Personal data

Tana handles all Personal data in accordance with the terms of this Privacy Policy and the legal obligations applicable to the processing of Personal data. Tana has adopted adequate measures to protect all the Personal data against accidental or unlawful destruction, loss, alteration, un-authorised disclosure of, or access to, Personal data transmitted, stored or otherwise processed.

Tana optimizes the security of the Personal data by i.a. using encryption, firewalls, password protections and limiting the access to the Personal data. However, the transmission of information via the internet can never be completely secure and the provision of Personal data remains at ones own risk at all times. If you have the impression that your Personal data is not adequately protected or if there are indications of abuse, please write at gdpr@tanacph.com.

e) User rights with regard to Personal data

Consultants, Individuals working in organisations and Clients have the right to:

• access their Personal data and to be informed about its use
• correct their Personal data
• have their Personal data deleted
• restrict the use of their Personal data
• ask for the portability of their Personal data

To exercise any of the above-mentioned rights, an email to gdpr@tanacph.com should be sent.

Cookies

Tana is constantly seeking to improve the experience of interested parties. That is why, for certain sections of the website, cookies are used. The website may contain web beacons.

Liability

Tana may not be held legally responsible, either from an express or tacit obligation, towards the Consultant for any indirect or direct damages resulting from submission of personal CVs.

The registered consultant hereby undertakes to regularly update its information.

The Consultant expressly acknowledges:

• That it is solely responsible for the accuracy of the information sent to Tana
• That Tana is free to share your data with relevant collaborators

Limitation of liability

The Consultant hereby acknowledges that Tana does not guarantee and is not liable for the contents of curriculum vitae of Consultants and profiles in the organisation database. The Customer is solely liable for the use it makes of the information provided by Tana.

Tana is not liable for any transaction entered into between its Customers and/or between its Customers and a third party. Under no circumstances shall Tana be a party to such transactions. Tana does not guarantee any minimum level of orders, income or results.

Ethical Guidelines

Tana-EHG Aps will at all times demonstrate the highest levels of integrity, truthfulness and honesty in order to uphold both personal and corporate reputations. Regardless the partners and where we may operate, Tana will conduct its business within the corridor of ethical principles outlined in this document. Tana also acknowledges the principles in the UN Global Compact, which are reflected below.

Human Rights

Tana embraces and complies with international convention on human rights. Tana is committed to avoid complicity in human rights abuses in our operations and in our assignment-related activities with special attention to vulnerable groups, including women, children, indigenous peoples and migrants. Any behavior or act violating human rights will not be tolerated.

Labor Condition

Tana is committed to treat all consultants, staffs and partners with dignity and respect with equal opportunities regardless of race, religion, gender, political and sexual orientation, maternity, marital status, family status, disability, age, or nationality. Tana offers a safe and healthy working environment and Tana will not tolerate any form of harassment, violence, intimidation, abuse of power, bullying as well as forced and/or child labor in relation to our operations and in our assignment-related activities.

Environment

Tana will take into account environmental aspects and the need to protect it and, when relevant, minimize the impact of its operation have on it. Tana put into consideration our environmental footprint when travelling in connection with our work. This implies that Tana will aim at taking the most direct route and avoid unnecessary travel activities.

Anti Corruption and Bribery

Tana does not allow any form of direct or indirect offer, payment, solicitation or acceptance of bribery and corruption. Any consultants, staffs and partners found and proven to be involved in any kind of corrupt practice will immediately receive termination of employee status or contract and may well have committed a criminal act, which could lead to prosecution. Tana is committed to not act corruptly in any of our dealings with other parties in relation to our service. Tana will also ensure that any third party acting on our behalf upholds the same principle against corruption.

We operate based on the basis of the following ethical values:

1. HONESTY. It is our objective to conduct and communicate our activities in an honest, truthful, properly told and well-presented manner. Tana will not seek to gain anything from misrepresentations, overstatements, partial truths, selective omissions or other forms of false communication. Clients should be given factual information about prices, schedules, service and other terms of business. Consultants, staffs and partners also deserve to be treated fairly, honestly and in accordance with agreed terms.
2. LOYALTY. Tana aims to maintain loyal and mutually beneficial relationship with all of our consultants, staffs, partners and clients without compromising our ethical values.
3. FAIRNESS. Tana is committed to not take unfair advantage through abusing arbitrary power, manipulation, and concealment, abuse of privileged information, misrepresentative communication, or any other unfair-dealing practice.
4. RESPECTS FOR OTHERS. Tana put high respect on human dignity, personal autonomy, privacy and human rights. All consultants, staffs and partners regardless of their colour, race, religion, marital status, sexual orientation, disability or age should be treated fairly and honestly with both respect and dignity.
5. COMPLIANCE. Tana will seek to comply with all international, national and local legislation related to all business activities. Tana will strive to follow the best practice in corporate governance. Tana will meet tax obligations. And Tana will not make any financial contributions or offer support to any political party.
6. COMMITMENT TO EXCELLENCE. Tana does not compromise on delivering high quality service. We therefore strive to stay well informed and prepared as well as continuously enhance our capacity in order to increase our proficiency in all areas of responsibility.
7. ACCOUNTABILITY. Tana has the obligation to fulfill our duties and accept responsibility for the consequences of our actions, be they positive or negative. We will cooperate and answerable to anyone particularly our clients and partners regarding our operations.

Any consultants, staffs or partners who violate our ethical standards will be subject to disciplinary action which can include verbal warning, written warning, suspension or termination of employment/contract.

Research Ethics

Research and evaluation should at all times adhere to the highest standards of integrity and ethics. In order to facilitate this Tana has drawn up Principles on ethical practice in research and evaluation process. All research and evaluation conducted by Tana (wholly or partially) is therefore expected to uphold these principles. At the core, these principles emphasize the need to produce good research and evaluation, and in the same time avoiding doing any harm to the participants as well as the consultants.

“Research” refers to any action or method to seek information from participants, such as interview, focus group discussion, survey, etc.

PRINCIPLES

1. Ethical approval and research permit.
   Consultants are responsible for identifying any requirements and obtaining any necessary ethical or research approval for the assignment they are undertaking. This is for example official research permit from national or local authorities in targeted countries, formal approval or confirmation from other stakeholder institutions and formal (or possibly informal depending the context) approval from local community leaders.
2. Quality of research.
   Research must be relevant, high quality and clearly in accordance with Term of Reference. It must be undertaken to a sufficiently high standard that the findings can be reliably used for their intended purpose. Research should only be undertaken where there is a clear gap in knowledge.
3. Do no harm.
   Consultants should avoid doing harm to participants in research. This includes (but not limited to) physical harm, psychological distress and discomfort, social disadvantage, harm to participants’ financial status and an invasion of participants’ privacy and anonymity. Consultants should ensure that the basic human rights of individuals and groups with whom they interact are protected. This is particularly important with regard to vulnerable people. The wellbeing and safety of consultants working in the field should also be considered and any harm or discomfort should be minimized to the extent necessary.
4. Informed consent.
   It means that (a) participants of research or evaluation should understand that their participation is voluntary and without having been coerced and/or deceived, and (b) they are clearly informed what the research and evaluation require from them. Information given to participants may include the organisation conducting the research, the purpose of the research, the methods being used, the possible outcome of the research and evaluation, as well as associated demands and all foreseeable discomforts, inconveniences and risks that the participants may encounter during and after their participation. Any material information that might influence participants’ willingness to give consent should not be withheld from participants.
5. Right to Withdraw.
   Participants should always have the right to withdraw from research or evaluation process and withdraw any data concerning them at any point without fearing any consequences. When a participant chooses to withdraw from the research process, they should not be pressured or coerced in any way to try and stop them from withdrawing.
6. Confidentiality, data protection and privacy.
   Consultants should ensure confidentiality of information, privacy and anonymity of research participants at all times. They should abide to the General Data Protection Regulation (GDPR) 2016/679 ensuring data protection and privacy for all individuals providing information. Consultants should clearly explain the limits to confidentiality to prospective participants. Consultants should also explain that if they hear or see something that gives cause for concerns, they have a duty to act. That might mean that consultants first encourage the person to talk to someone who could help, or agree that the consultants can talk to someone else on their behalf. In exceptional circumstances such as encountering a serious wrong-doing (e.g. corruption or abuse), it may be necessary for the consultants to breach confidentiality without first talking to the participant considering the ethical need to prevent harm to vulnerable people.
7. Commitment to Human Rights.
   Consultants should conduct the research in accordance with international human rights conventions and covenants to which Denmark is a signatory, regardless of local country standards. They should also take account of local and national laws.
8. Culturally Sensitive Research.
   Consultants should adopt culturally sensitive approach thus mutual understanding and trust can be fostered and eventually optimal outcome can be obtained. This means, from planning the research until communicating findings, consultants should take account and respect differences in culture, local behaviour and norms, religious beliefs and practices, sexual orientation, gender roles, disability, age and ethnicity and other social differences such as class.
9. Transparency, Openness and Fairness.
   Tana is fully committed to transparency and openness in publication, communication and dissemination of all evaluations and research. Transparency includes, but not limited to, reporting: (a) full methodological details and (b) information on who has undertaken the research, and (c) material and financial resources supported the research. By fairness, Tana aims to communicate the research fully and fairly reflect the findings. Tana is also open to the sharing of scientific resources, such as methods, measures and (non-personal) data in order to further social science advances. Where possible, and respecting confidentiality requirements, primary data should be kept in files within Tana to allow secondary analyses.
10. Equal Participation.
    In conducting research, consultants should be inclusive in selecting participants. Consultants shall not exclude individuals as potential participants on the basis of attributes such as gender, race, ethnicity, age, religion, disability and sexual orientation, unless there is a valid reason for the exclusion. Consultants should ensure participation of women and socially excluded groups when relevant. Consideration should however be given to how barriers and risks to participation can be removed.

Sexual Harassment Policy

1. Purpose
   In Tana-EHG we won’t tolerate sexual harassment in any shape or form. Our culture is based on mutual respect and collaboration. Sexual harassment is a serious violation of those principles. Our sexual harassment policy aims to protect all employees in Tana-EHG from unwanted sexual advances and give them guidelines to report incidents.
2. Scope
   This policy applies to every person in Tana-EHG regardless of gender, sexual orientation, level, function, seniority, status or other protected characteristics. We are all obliged to comply with this policy. We won’t tolerate sexual harassment from inside or outside of the company. Employees, external sub-contractors and clients, everyone interacting with our company are covered by the present policy.*
3. Definition
   Sexual harassment has many forms of variable seriousness. A person may sexually harass someone when they:
   • Comment on someone’s looks, dress, sexuality or gender in a derogatory or objectifying manner or a manner that makes them uncomfortable.
   • Invade another person’s personal space (e.g. inappropriate touching.)
   • Make obscene comments, jokes or gestures that humiliate or offend someone.
   • Send or display sexually explicit objects or messages.
   • Insinuate, propose or demand sexual favors of any kind.
4. How to handle sexual harassment
   An employee should never hesitate to express if his/her limits are exceeded. If an employee experiences sexual harassment, he/she must clearly communicate that he/she is uncomfortable with the situation, and then report the event to the management team. It must always be clearly respected if an employee communicates that an act is harassing, even if the accused finds the action innocent.
5. If you witness sexual harassment
   If an employee witnesses harassment, it is first and foremost important not to contribute any further to the harassment, for example by laughing. Next, it is the duty of the witness to take a stand against the situation, for example by referring to this policy. It is advised to talk to the person who is being harassed to clarify if his/her limits have been exceeded. If this is the case, one should help and support his/her colleague to contact the management so that action can be initiated immediately.
6. The procedure
   In the event of a complaint / prosecution, as described in this policy, the management will arrange to intervene. The management team will:
   • Initiate a dialogue with the employee who has filed the complaint for a detailed description of the event, including who, when and where the harassment occurred
   • Initiate a dialogue with the employee/external who is accused, in order to determine whether he / she has the same view on the case
   • In some cases it will be necessary to convene possible witnesses to determine whether sexual harassment has taken place.
   The management will make sure to consider both descriptions of the situation and process the complaint as quickly as possible, while keeping in mind that all parties involved are entitled to fair treatment. Management will of course display the necessary discretion and protection of the dignity and privacy of the involved. There will not be disclosed any information about the matter to unauthorized persons. Depending on the severity of the event, and the level of supporting documentation, the management selects whether to impose employment law sanctions, relocations, and possibly psychological treatment if needed.

Tana’s Gender and Social Inclusion Policy

Gender Equality and Social Inclusion (GESI) is a core part of Tana-EHG’s work and operations as is evident from our many targeted projects aimed specifically at enhancing gender equality and women’s empowerment as well as in all other projects where we constantly work to ensure a focus on GESI in all aspects of our work.

Tana and its consortium members work on analysing any part of our work against the following questions:

1. What are the contextual and political-economy factors which affect GESI on the given assignment
2. How can we ensure that our work improves the GESI situation in a way that do no harm
3. In what way can we learn and adapt our project as we become more knowledgeable of what works to enhance the GESI agenda

While GESI may not be explicitly referenced in the client’s terms of reference, Tana works to ensure attention to the issue in any assignment with a focus on adhering to the human rights commitments.

GESI in research and studies

Research undertaken by Tana in most cases informs policy making and project design. Ensuring GESI in the research and studies undertaken is thus a requisite for ensuring that GESI is included in all the other phases of the project implementation cycle. To guide the GESI inclusion in any Tana research, the following questions are sought addressed:

1. What are the more objective GESI issues that need to be taken into consideration (e.g. literacy rates; women’s and minority groups representation in e.g. parliament and leading positions in government; health indicators; access to finance; laws on inheritance; statistics on gender based violence (GBV); women and minority casualties in conflict)
2. What are the potential political-economic and contextual/conflict factors that inhibit GESI ...
3. What opportunities do the political-economy and context include that can improve GESI ...
4. How can the research be designed so that it is inclusive and participatory and thus ensures that women and minority groups are heard and included sufficiently, while taking ethical considerations to ensure that no harm is done ...

GESI in the design phase

1. GESI targeted activities in the project
2. GESI defined outputs and outcomes
3. GESI related indicators
4. Policy on representation of women and minority groups among project staff and management arrangements ...
5. Policy on women and minority representation in capacity development activities ...
6. Monitoring and safeguard design to ensure GESI advancement as well as do no harm ...
7. Ensure potential sub-contractor GESI capacity ...
8. Design adherence and promotion of the human rights conventions and UN Security Council Resolution 1325 ...

GESI in the implementation phase

1. Ensuring GESI capacity among staff
2. Ensure relative representation of women and minorities among project staff
3. Ensure GESI as part of ongoing project progress analysis
4. Report on GESI indicators ...
5. Monitor women and minorities representation in project activities
6. Ensure GESI reporting is part of steering committee agenda
7. Ensure GESI in policy dialogue with government ...
8. Ensure emergency response preparedness ...

GESI in monitoring and evaluation

1. Relative representation of women and minority groups in interview samples
2. Assessing project attention to and implementation of GESI activities
3. Assessing possible unattended positive and negative side effects of project on GESI
4. Focusing on the outcome and impact of the project on GESI ...

GESI on Tana operations and in the Tana office

1. Ensuring strong representation of women and minority groups on project teams
2. All project teams include experts with specific GESI expertise
3. GESI considered when finding consortium partners ...
4. Capacity and policies on GESI of sub-contractors
5. Tana always has a strong in-house capacity on GESI
6. GESI part of the quality assurance process
7. Gender balanced staffing (currently ~48% male, ~53% female)
8. Encouraging balanced and minority representation in internships
9. GESI part of the yearly strategy process

Safeguarding Policy

1.1 PURPOSE OF THE POLICY

This Safeguarding policy is intended to outline our organisation’s approach, practice and commitment to ensuring a comprehensively safe environment for all people that the organisation engages with. We intend to share this policy whenever relevant with staff and associated working with and for Tana-EHG ApS in order for them to be familiar with Tana’s commitment to safeguarding. This Policy is an overarching umbrella policy, which should be seen in connection to our other policies, guidelines and codes of conduct which guide our work, and which illustrate our ongoing commitment to be an ethical and responsible service provider. Subsequently the “do no harm” principle is recognised as an important element in the strengthening of our safeguarding system.

1.2 POLICY STATEMENT

Tana-EHG is committed to ensuring a safe and trusted environment which safeguards anyone who we have contact with, including beneficiaries, staff and partners. We are committed to fostering an organisational culture that prioritises safeguarding, so that it is safe for those affected to come forward, and to report incidents and concerns with the assurance that they will be handled sensitively and properly. This includes having the adequate safeguarding policies, procedures and measures to protect people and that these are shared and understood.

1.3 WHAT IS SAFEGUARDING?

Tana uses the DFID broad definition of Safeguarding (1): “Safeguarding in its broad sense means protecting people and the environment from unintended harm”. We further consider Safeguarding as a threefold commitment that applies across programmes, partners and employees:

1. Prevention – Taking responsibility to identify and minimise the risk of harm to people – particularly vulnerable adults and children – and the environment, in whatever form it might occur to avoid it from happening in the first place. This is closely related to our Gender and Social Inclusion Policy.
2. Protection – Ensuring that we have the adequate, accountable and transparent systems in place to respond, report and learn when risks materialise.
3. Response – Safeguarding that any complaint, violation or harm done will be dealt with appropriately and with care by having the right response system. The system should be able to respond to harm caused by sexual exploitation, abuse, harassment or bullying.

The aim of these three pillars is to minimise the likelihood and impact of these actions towards both the aid beneficiaries, and also people who are working in the aid sector. It entails a wide potential range of policies, procedures and activities seeking to address the safety and wellbeing of the people we work with (1.6 presents the associated Tana policies) and ensuring that no abuse of power or relationships will take place (in line with our Sexual Harassment Policy).

1.4 PRINCIPLES OF SAFEGUARDING

• Everyone has responsibility for safeguarding
• We commit to the principle of ‘Do no harm’
• We take our safeguarding duty of care seriously and are also committed to ensuring that our downstream partner part of delivery have the necessary knowledge and systems in place to safeguard.
• We act with integrity and in accordance with the human rights-based approach principles of participation, accountability, non-discrimination and inclusion.
• All our activities consider the best interest of children (someone under the age of 18) and other vulnerable persons. Furthermore, all children and adults shall be treated equally, irrespective of race, gender, religion/or none, sexual orientation or disability.
• In all our work we conduct solid risk assessment and risk management plans, particularly for assignments in sensitive contexts or where there is deemed high reputational, ethical or professional risks.
• We are committed to protecting personal and sensitive data in line with our internal data breach guidelines and the European General Data Protection Regulation 2016/679. We have the systems in place ensuring that we can handle confidential and sensitive data both virtually as well as physically. All Tana employees also have the necessary protection programs installed on the computers (including antivirus, anti-spyware and firewall software).

Tana staff are obliged to follow these principles. Our external consultants and partners should also conduct themselves in line with Tana’s Code of Conduct and policies.

1.5 REPORTING A CONCERN OR A SUSPECTED BREACH

Tana is committed to spreading the awareness of our Safeguarding Policy and employing a system that permits safe and accessible reporting of safeguarding concerns from employees and the communities in which we work. We have regular staff trainings, procedures for reporting a suspected breach (or any other related issues such as sexual harassment, ethical, corruption etc.) and associated consultants are clearly informed in their contracts of such reporting mechanism.

Our reporting mechanism is outlined in our Whistleblower Policy and Sexual Harassment Policy. Employees who have a complaint or concern relating to safeguarding should report it immediately to Tana’s Managing Director in person or via e-mail to eb@tanacph.com. Reports can also be done anonymously via mobile phone (+45 3536 1915) or mail (info@tanacph.com).

1.6 ASSOCIATED POLICIES

The Safeguarding Policy complements our other policies and codes of conduct which guide our work and set out the principles of our professional engagement with clients, partners and beneficiaries. We are committed to identifying safeguarding needs and setting policies for our employees and associates to follow. We also expect our partners and suppliers to apply similar measures within their organisations. This Safeguarding Policy is associated to the following mother Tana policies and codes of conduct, which all apply to all Tana staff and associated consultants:

• Tana Integrity Policy & Code of Conduct
• Tana Gender and Social Inclusion Policy
• Sexual Harassment Policy
• Tana Whistle-blowers Policy
• Tana Privacy Policy
• Research Ethics Policy
• Ethical Guidelines
• Environmental Policy
• Tana’s Security Policy (available upon request)
• Data Breach Guideline (available upon request)
• Tana Quality Assurance Guideline (available upon request)

Whistleblower Policy

Tana is committed to ensure its own policies — as well as its clients — are adhered to the high integrity standard at all times. Tana is also committed to report any illegal behavior/act/event when we and/or any of our partners evidence it. In such cases, reports will be provided to the management forthwith and immediate investigation and appropriate actions will be taken.

This policy is therefore intended to encourage anyone including Tana’s staffs, former staffs, clients and partner to report suspected or actual occurrence(s) of illegal, unethical or inappropriate behavior/act/event without fearing retaliation or retribution.

1. Tana’s internal staffs, former staffs, sub-consultants and others partners (the Whistleblower) should make a report to his/her supervisor if they have a suspicion of corruption or unethical behavior/event such as (but not limited to):
   • Any abuse of human rights
   • Any violation of law, regulations and internal policies
   • Misbehavior with regard to accounting and auditing
   • Fraud, theft and other illegal practices
   • Improper giving or receiving gifts (bribery and corruption)
   • Scientific research misconduct
   • Discrimination and harassment in any form
   • Breaching of data security as well as misuse of Tana’s database
2. In a situation where a whistleblower feels uncomfortable or uneasy to report the suspicious behavior/act/event directly to the supervisor, the whistleblower can report it to the Tana Senior Management in person or via mail to eb@tanacph.com.
3. The Whistleblower can also be anonymous and report the suspicious behavior/act/event via mobile phone (+45 3536 1915) or mail (info@tanacph.com). However, Tana encourages whistleblowers to provide name and contact detail in order to make it easier for the management to address the case.
4. Tana will not discharge, suspend, harass, discriminate nor give retribution against the Whistleblower who makes a report with respect and in good faith without any intention to damage Tana, the staffs, clients and partners. Anyone who retaliates against the Whistleblower will be subject to discipline, including termination of employee status.
5. A Whistleblower who makes a report that is not done in good faith and with malice to harm Tana, its staffs, clients and partners is subject to discipline, including termination of the employee status or consultancy, or other legal means to protect the reputation of Tana-EHG, clients, partners or affected staff.
6. Any crimes against person or property, such as assault, rape, burglary, etc. will immediately be reported to local law enforcement personnel.
7. Supervisors or managers who receive the reports must promptly act to investigate and/or resolve the issue. As part of this process the manager must immediately inform Tana senior management.
8. Within five business days, whistleblower shall receive a feedback from his/her report and an update regarding the investigation process, disposition or resolution of the case.
9. Should the whistleblower not be satisfied with Tana’s internal management investigation and suspect the investigation is not conducted in good faith, he/she has the right to report the case to law enforcement agencies.
10. Tana will ensure confidentiality of the whistleblower, unless the issue requires investigation by law enforcement and members of the organisation are subject to subpoena.

GDPR

The Consultant or other persons accessing Tana’s website acknowledges that the lay-out as well as any item appearing on the Tana website, in particular, but not limited to, the texts, data, projects, databases, graphics, images, designs, logos (hereinafter the “Contents”), are protected by copyright. Any reproduction, adaptation, translation, or public communication of the Contents, or any part thereof, is subject to the prior and written approval of Tana.

The Consultants or other persons accessing the website are not authorised, whether for commercial or purely complimentary means, to copy, reproduce, transmit, distribute or translate all or part of the Contents without the prior and written permission of Tana. The Consultant or other person may not use the Personal data available on the website for marketing purposes.

Tana may insert hypertext link in its pages. However, Tana is not responsible for the contents that appear on the sites of these third parties.

Applicable law
The Privacy Policy & Terms of Use of the Tana website, together with the different relations between Tana and its Consultants are governed by the Danish law, independently of any other jurisdiction. The failure of Tana to exercise the rights granted herein does not mean that it waives its rights to enforce these rights. Should any dispute arise from this contractual relationship, the parties hereby undertake to seek a friendly settlement before going to court.