Situation
A youth employment NGO operating in four Iraqi governorates with ICRC funding was required to produce a comprehensive governance and compliance documentation suite as a condition of continued funding. Required documents included a code of conduct, forced labour policy, anti-corruption policy, and conflict of interest framework. The NGO had no compliance function and had never produced this class of documentation. Failure to submit by the deadline would suspend USD 380,000 in active program funding affecting 1,200 beneficiaries.
Complication
ICRC standards required alignment with the UN Guiding Principles on Business and Human Rights. Field operations in Anbar, Fallujah, and Hillah created safeguarding obligations that went well beyond standard commercial compliance frameworks. Board members held positions in four other organizations, creating a conflict of interest landscape requiring careful mapping. One board member had a commercial relationship with a supplier the NGO used — requiring careful handling to document accurately without mischaracterizing it.
The Critical Decision — What Almontather Rassoul Saw and Did Differently
When I identified the board member's commercial supplier relationship, I had to decide how to present it in the conflict of interest register. An aggressive reading would have classified it as a material conflict requiring immediate divestiture or resignation. A more measured reading — which I concluded was correct given the nature and scale of the relationship — classified it as a declared interest requiring management rather than elimination. I presented both readings to the executive director with my recommendation. She accepted the managed interest classification, which was disclosed fully in the register. ICRC reviewed the register without comment, validating the approach.
Methodology — Why This Approach and Not Another
I chose to cross-reference every document to specific ICRC Supplier Code clauses and UN Guiding Principles articles rather than producing standalone policies because ICRC's review process is structured around those references. A standalone policy that accurately captured the substance but did not signal alignment to the specific framework ICRC uses would have created unnecessary review questions.
Resolution — Delivered by Almontather Rassoul / MRC Firm Ltd.
A ten-document compliance suite covering all ICRC requirements and extending to safeguarding, beneficiary data protection, and grievance redress mechanisms for field operations with vulnerable populations. Each document cross-referenced to the relevant ICRC Supplier Code clause and UN Guiding Principles article. A board conflict of interest register designed and populated. All ten documents accepted by ICRC without revision. ICRC subsequently shared the framework as a reference model with two other Iraqi NGO partners.
What Was Not Fully Resolved — and Why
The NGO's capacity to maintain and update the compliance framework independently following the engagement was limited by its staffing structure. I recommended appointment of a part-time compliance officer as a condition of the next funding cycle. That recommendation was accepted in principle but had not been implemented at time of document production.
“Rassoul understood both the technical ICRC requirements and the political sensitivity of the board disclosure process. Both needed to be handled precisely. He got both right. The fact that ICRC used our framework as a model for other partners was something we had not anticipated.”
— Executive Director, Youth Employment NGO
Consultant: Almontather Rassoul, PhD · MRC Firm Ltd. · montather-rassoul.com · linkedin.com/in/montatherrassoul