Governance & Compliance

At ASCEND (Alliance for Sustainable and Competitive Economic & National Development), we are committed to advancing sustainable development, equity, and innovation through ethical leadership, robust governance, and full legal compliance. Our internal framework aligns with the German Geldwäschegesetz (GwG), the EU Anti-Money Laundering Directives, the OECD Guidelines for Multinational Enterprises, and principles set by the UN Global Compact.This section outlines our policies on: Code of Conduct, Anti-Money Laundering (AML), Governance Structure and Compliance Framework.

1. Code of Conduct

Our Code of Conduct applies to all staff, board members, consultants, volunteers, and partner organizations working with or on behalf of ASCEND.

Ethical Foundation:

• Legality: All activities must fully comply with applicable German, EU, and international laws.

• Human Rights & Equity: We uphold universal human rights and promote social inclusion regardless of gender, race, ethnicity, religion, disability, or background.

• Integrity & Honesty: All interactions, both internal and external, must be conducted with honesty, fairness, and transparency.

• Accountability: Staff and leadership must be accountable for their actions and decisions.

Operational Conduct:

• Conflict of Interest: Employees must avoid situations in which personal interests conflict with organizational duties. Conflicts must be disclosed to the Compliance Officer.

• Use of Resources: Organizational assets (including funding, data, and reputation) must be used responsibly and for designated purposes only.

• Harassment-Free Workplace: We maintain a zero-tolerance policy for harassment, discrimination, or abusive behavior.

Oversight & Enforcement:

• Violations of the Code are subject to investigation and may result in disciplinary or legal action.

• Reports of misconduct can be submitted confidentially to compliance (at) globalascend (dot) org or via our protected whistleblower channel.

2. Anti-Money Laundering (AML) Policy

ASCEND is committed to combatting all forms of money laundering, terrorist financing, and illicit financial flows in line with the German Money Laundering Act (GwG) and FATF (Financial Action Task Force) standards.

AML Framework Components:

• Customer Due Diligence (CDD):

  • Verification of identity and beneficial ownership for all significant donors, partners, and contractors.

  • Enhanced due diligence (EDD) for politically exposed persons (PEPs), foreign clients, or high-risk geographies.

• Ongoing Monitoring:

  • All financial transactions are monitored for anomalies.

  • Financial records are maintained and audited in accordance with § 8 and § 10 GwG.

• Suspicious Activity Reporting:

  • Any suspicion of money laundering or terrorist financing is reported immediately to the FIU (Financial Intelligence Unit) via the goAML system, per § 43 GwG.

• Training & Awareness:

  • All relevant personnel receive periodic training in AML compliance.

  • Internal policies are regularly reviewed and updated in light of legal changes or risk assessments.

ASCEND is registered as an obligated entity under § 2 GwG, owing to its international operations and exposure to financial flows from multiple jurisdictions.

3. Governance Structure

ASCEND operates with a transparent and accountable governance structure consistent with German non-profit law (gGmbH and Vereinsrecht), EU governance frameworks, and best practices from leading policy organizations.

Key Governance Bodies:

• Managing Director (Geschäftsführer): Oversees strategic implementation, staffing, and compliance.

• Supervisory Board (to be installed): Provides oversight, approves annual plans and budgets, and ensures independent control functions.

• Advisory Councils: Each of our six thematic pillars is supported by an expert advisory body to ensure relevance and impact.

Governance Practices:

• Board Independence: All board members must act in the interest of ASCEND, not for personal gain or external lobbying.

• Transparent Decision-Making: Major decisions are documented, traceable, and aligned with our articles of association and mission.

• Financial Oversight: Annual audits, public reporting, and budget approvals are managed through documented procedures and review mechanisms.

• Diversity & Participation: Our governance aims to reflect the diversity of stakeholders across sectors and geographies.

4. Compliance Program

Our Compliance Program ensures that ASCEND operates in full accordance with national and international legal requirements, donor regulations, and ethical standards.

Compliance Elements:

• Legal Compliance: We comply with German regulations (GwG, AO, HGB), EU laws, and applicable donor requirements (e.g., BMZ, EU Commission).

• Data Protection: Personal and partner data is managed in line with the EU GDPR, including data minimization, encryption, and access controls.

• Whistleblower Protection:

  • Whistleblowers are protected from retaliation under the EU Whistleblower Directive (2019/1937) and its German implementation (Hinweisgeberschutzgesetz).

  • Anonymous and confidential reporting options are available via our reporting tool.

• Sanctions Screening: ASCEND screens all third parties and transactions against international sanctions and watchlists (EU, UN, OFAC).

• Export & Cross-Border Compliance: We ensure that cross-border research, training, and financial flows comply with all applicable foreign trade and export control laws.

Continuous Improvement:

• Internal audits and risk assessments are conducted annually.

• Our compliance system is reviewed and adapted regularly to reflect operational changes and regulatory updates.