Zero tolerance for corruption in any form.

Purpose

Class2Class operates an international platform that connects classrooms, partners, and funders across more than 160 countries. Trust is the foundation of every relationship — with the children we serve, with the teachers and schools who use the platform, with the donors and partners who support our mission, and with the regulators who oversee our work.

This policy defines what corruption is at Class2Class, what we will not do, what we will do when we suspect it, and how we hold ourselves accountable. It operationalises the public commitment on this page and provides the institutional backing for the Code of Conduct and the Reports Handling and Whistleblower Procedure.

Our commitment

Class2Class commits to:

• Fair, transparent, and accountable decision-making in hiring, procurement, partnerships, and programme management
• Refusal of corrupt benefit — neither offering nor accepting any benefit that is intended to, or could reasonably be perceived to, improperly influence a decision
• Disclosure — every conflict of interest is declared; no decision is made under undisclosed conflict
• Merit-based selection — every hiring decision, every procurement decision, every partnership decision is made on the merits, against transparent criteria
• Cooperation with authorities — Class2Class cooperates with Danish, EU, and other competent authorities investigating corruption, within the bounds of GDPR Chapter V and Danish law
• Protection of reporters — anyone who reports suspected corruption in good faith is protected from retaliation, in line with the EU Whistleblower Directive and the Reports Handling and Whistleblower Procedure

Regulatory framework

This policy adopts the criminal-law standards above as a floor, and applies stricter institutional standards where appropriate.

Scope — who and what is covered

This policy applies to every individual acting on behalf of Class2Class, regardless of contractual status:

• Employees of Class2Class ApS
• Board members and advisors
• Volunteers, interns, and fellows
• Consultants and contractors engaged to deliver work for Class2Class
• Country coordinators and regional representatives
• Partners — schools, NGOs, and others — when acting on Class2Class's behalf
• Suppliers — to the extent that this policy is incorporated into the supplier contract

Every person above acknowledges this policy in writing before engagement begins, by signing the Commitment to Safeguarding declaration. The signed declaration is renewed annually.

The policy applies to conduct on duty and to conduct outside working hours where the conduct concerns Class2Class business or the representation of Class2Class — in line with Code of Conduct §3 (around-the-clock applicability).

Definitions

The full glossary is in the institutional document. Two definitional anchors:

Other defined terms include public-official bribery (treated with the highest severity), private bribery (Danish Penal Code §299), facilitation payment (prohibited even where local custom permits), extortion, fraud, embezzlement, favouritism / nepotism, conflict of interest, gift, hospitality, donor, and beneficial owner.

Prohibited conduct

6.1 Bribery

6.2 Fraud and embezzlement

6.3 Extortion

6.4 Favouritism, nepotism, and undisclosed conflict

6.5 Misuse of position

6.6 Retaliation

Conflicts of interest

Conflicts of interest are not, in themselves, misconduct. Undisclosed conflicts are.

7.1 Disclosure obligation

Every person to whom this policy applies discloses, in writing, any actual, potential, or perceived conflict of interest:

• At engagement — as part of the Commitment to Safeguarding declaration
• On change — as soon as reasonably possible after a new conflict arises
• Annually — in the annual re-signing of the declaration
• Before any decision the person participates in where the conflict is material to the decision

Disclosure goes to the DPO as the central register holder, with a copy to the CEO. Where the disclosure concerns the DPO or the CEO, it goes to the alternate route in §7.4.

7.2 Examples of conflicts that must be disclosed

Illustrative, not exhaustive:

• A family member, partner, or close friend works for, owns, or controls a Class2Class supplier, partner, or funder
• A representative is a member, director, or paid adviser of a partner organisation
• A representative has a financial interest (shares, options, paid consulting) in any entity that does business with Class2Class
• A representative is involved in a hiring decision concerning a relative, partner, or close personal connection
• A representative has accepted a gift or hospitality from a counterparty, above the §8 threshold
• A representative is in a romantic, sexual, or close personal relationship with another representative where one has supervisory authority over the other
• A representative is involved in a procurement decision concerning a vendor they have previously worked for or with
• A representative simultaneously holds a role at a competing or conflicting organisation

7.3 Recusal and management

7.4 Where the DPO or CEO is the conflicted person

Where the DPO is conflicted, the disclosure goes to the CEO. Where the CEO is conflicted, the disclosure goes to the Independent Reviewer at [email protected]. Where both are conflicted, the disclosure goes to the Board of Directors or the designated independent oversight contact.

Gifts and hospitality

8.1 Principles

Gifts and hospitality are part of normal professional life. They become a corruption risk when they are intended to, or could reasonably be perceived to, influence a Class2Class decision. The principles:

• Transparency over discretion — declared, modest, and infrequent is acceptable; concealed is not
• Proportionate and reasonable — a value that a reasonable observer would view as ordinary professional courtesy
• Never cash or cash-equivalent — no money, vouchers, gift cards, or anything that converts directly to money
• Never around a decision — no gift or hospitality from a counterparty in the period leading up to, during, or immediately after a decision Class2Class is making about that counterparty
• Reciprocal and contextual — a meal with a partner during a working visit is normal; a luxury weekend trip is not
• Cultural context, not exception — local custom does not unlock anything that this policy otherwise prohibits

8.2 Threshold

Below the €50 threshold and not more frequent than twice per year from the same counterparty, gifts may be accepted without prior approval but must be recorded. Above the threshold, prior approval from the DPO or CEO is required, and the gift is recorded regardless of approval outcome.

Gifts that would breach the threshold but are sent unsolicited are politely returned with a brief note explaining this policy. Where return is impractical, the receiver records the gift in the register and donates the equivalent value to a charitable cause unrelated to Class2Class.

8.3 Gifts to public officials

Fair hiring

Hiring decisions are merit-based and follow a documented process.

9.1 Principles

• Open to qualified candidates — positions are advertised through channels appropriate to the role; no "hire by tap on the shoulder" for any salaried role
• Objective criteria — criteria are written down before candidates are reviewed
• Diverse panels where practical — at least two interviewers, ideally including someone outside the immediate team
• Equal treatment — no preferential treatment based on family relationship, friendship, country of origin, gender, religion, or any other ground that is not lawful under Danish and EU non-discrimination law
• Documented decision — the reasoning for each hiring decision is recorded and retained for the period required by law

9.2 Conflicts in hiring

A representative who is involved in a hiring decision concerning a relative, partner, or close personal connection discloses the conflict before the process begins (per §7.1) and recuses from the decision.

9.3 References

Reference checks are part of every salaried hire and every long-term engagement. References are sought from professional sources, with the candidate's consent.

Fair procurement

10.1 Procurement thresholds

10.2 Vendor due diligence

For every supplier above the €10,000 threshold and every strategic supplier, due diligence includes:

• Identity check — legal entity, beneficial owner, registered office
• Sanctions screening — against EU and UN sanctions lists; against the consolidated list maintained by the Danish Ministry of Foreign Affairs
• Anti-corruption screening — any prior public findings or sanctions for corruption-related offences
• Data-protection due diligence — per DPA Template Appendix B
• Conflicts check — confirmation that no Class2Class representative has an undisclosed interest in the supplier

10.3 Conflicts in procurement

A representative who has an interest in, or a connection with, a supplier under consideration discloses the conflict before the process begins and recuses from the decision.

Donors and funders — due diligence

Class2Class accepts financial and in-kind support from individuals, foundations, public bodies, and companies. We do not accept support that compromises our independence, our values, or our zero-tolerance position on corruption.

11.1 Principles

• Mission alignment — a donor's purpose must be compatible with Class2Class's mission and these guidelines
• Independence — donor support does not buy editorial control over our content, our research, our policy positions, or our programme decisions
• Transparency — major donors are disclosed publicly in the Annual Transparency Report, subject to donor preference for anonymity expressed in writing
• Source-of-funds — verification appropriate to the size of the donation and the nature of the donor

11.2 Donor due diligence — tiered

11.3 Refusal and return

Class2Class may refuse a donation, or return a donation already received, where the donor's identity, beneficial owner, or source of funds cannot be verified; where the donor or funds are subject to sanctions; where public information indicates a serious risk that the donation is the proceeds of corruption, fraud, or other crime; where acceptance would compromise Class2Class's independence; or where acceptance would create an unmanageable conflict of interest.

11.4 Restricted funding

Where a donor restricts a donation to a specific programme, the restriction is honoured only where it is compatible with this policy and with the Code of Conduct, Child Safeguarding Policy, and Ethical Guidelines. We do not accept donor restrictions that direct programme content in ways that compromise child safeguarding, accuracy, or our values.

Reporting suspected corruption

12.1 Internal channels

12.2 External channels

Internal channels do not replace the right to report to a competent authority. Reporters may, at any time, report to:

• Statsadvokaten for Særlig Økonomisk og International Kriminalitet (SØIK / Bagmandspolitiet) — the Danish Public Prosecutor for Serious Economic and International Crime
• The Danish Police (politi.dk)
• The European Public Prosecutor's Office (EPPO) where EU funds are involved
• The European Anti-Fraud Office (OLAF) where EU funds are involved
• The competent authority in the country where the suspected conduct occurred
• Datatilsynet ([email protected]) where personal data is involved
• The independent national authority designated under the Danish implementation of the EU Whistleblower Directive

12.3 Anti-retaliation

Investigation and response

13.1 Severity

13.2 Investigation methodology

Investigations follow the Reports Handling and Whistleblower Procedure §6 methodology, with these additions specific to anti-corruption:

• Evidence preservation — financial records, communications, contracts, bank records (within scope) are preserved without modification
• External counsel is engaged for any High-severity case before any subject of the report is informed of the investigation
• External forensic support is engaged where the technical complexity exceeds in-house capacity
• Parallel referral — a High-severity case is referred to the appropriate competent authority without delay, regardless of the internal investigation's progress
• No internal cover-up — the CEO does not authorise, and the Board does not accept, any approach that conceals the conduct from competent authorities

13.3 Sanctions

Civil recovery and criminal referral are not alternatives to internal sanctions; they run in parallel where the conduct so warrants.

Records

The DPO maintains the following registers, all reviewed in the annual review:

Training and awareness

Review and accountability

This policy is reviewed annually by the DPO and the CEO. Material change to applicable law, the funding mix, or any High-severity case triggers an immediate ad-hoc review. The annual review feeds the Compliance Scorecard, the Annual Transparency Report, and the next version of this policy.