Esuku Development Foundation (EDEVF)

The name of the organisation shall be Esuku Development Foundation (EDF). The Foundation shall be registered as Incorporated Trustees under Part F of the Companies and Allied Matters Act, 2020, operating as a non-profit, non-partisan, and charitable entity dedicated to public benefit.

The Foundation shall have perpetual succession and a common seal, may sue and be sued in its corporate name, and may acquire, hold, or dispose of property necessary to realise its lawful objectives.

The registered office shall be located in Tamigbe Community, Burutu Local Government Area, Delta State, Nigeria. The Foundation shall maintain an operational presence in Delta State and the broader Niger Delta Region as required by its projects and partnerships.

Vision: To empower the Niger Delta Region through holistic education, human development, and transformative social engagement, thereby nurturing competent, ethical, and compassionate leaders.

Mission: To provide access to quality education, foster competency development, and promote socio-economic empowerment and environmental sustainability.

The Foundation shall embody values of integrity, inclusivity, accountability, and transparency in all undertakings. These statements constitute the moral and institutional compass of EDF and shall be reflected in all strategic, operational, and public documents.

The objectives of EDF are to:

Establish a modern library and e-learning infrastructure to expand access to knowledge and lifelong learning.

Provide scholarships and educational support to indigent students to enhance educational equality.

Implement empowerment programmes that promote entrepreneurship and self-reliance among youths and adults.

Develop a model private educational institution that upholds excellence, ethics, and community service.

Promote digital literacy and technological inclusion as tools for social mobility.

Strengthen community engagement through partnerships with government, civil society, and private sector actors.

Advance environmental education to promote ecological balance and sustainability.

Build the capacity of educators, professionals, and leaders for societal transformation.

Institutionalise monitoring, evaluation, and learning (M&E) systems to ensure accountability and continual improvement.

These objectives shall be implemented through strategic plans, annual budgets, and Board-approved programmes.

The operations and decisions of EDF shall be anchored on the following core values:

Excellence: Pursuit of the highest standards in service delivery and governance.

Education: Commitment to the transformative power of learning and critical thinking.

Human Empowerment and Environmental Sanitation: Enabling individuals and communities to thrive while preserving the environment.

Personal Growth: Encouraging continuous learning and intellectual renewal among members and beneficiaries.

Advocacy: Championing justice, peace, and equitable development in the Niger Delta region.

Partnership: Building collaborative relationships for sustainable impact.

Leadership: Promoting ethical, transparent, and visionary leadership at all levels.

To realise its objectives, EDF shall have the power to:

Design and implement programmes and projects consistent with its mission.

Acquire, hold, lease, or dispose of property lawfully.

Employ staff and engage consultants or volunteers.

Receive donations, grants, endowments, and lawful contributions from individuals or organisations.

Enter into contracts, open bank accounts, and invest its funds prudently.

Collaborate with governmental, private, and international institutions for mutual development.

All powers shall be exercised solely for public benefit and in accordance with Nigerian law.

All income and property of EDF shall be applied exclusively for the promotion of its objectives.

No trustee, member, or staff shall benefit from the Foundation’s income except through legitimate remuneration for services rendered or reimbursement of verified expenses.

This ensures that EDF remains a strictly non-profit and public-interest institution.

EDF shall function as a trustee-governed foundation without a general membership structure. However, it may recognise and engage categories of Associates, Fellows, Partners, and Volunteers.

The Board may organise annual stakeholder forums to present audited accounts, programme outcomes, and strategic priorities, thereby fostering transparency, learning, and community ownership.

The Board of Trustees (hereinafter referred to as “the Board”) is the apex governing body responsible for EDF’s strategic direction, policy oversight, and institutional integrity.

Inaugural Trustees:

Chief (Dr.) Akpobolokami Andy Mezeh – Chairman

Cmr. Togo Ojobokeme – Vice-Chairman

Evang. Zenetubor Pelle Emeleakpo – Secretary

Agbogidi Tam Fabian – ICT & Compliance

Pastor Paddy Boye Peretu – Treasurer

Evang. Salvation Amadi – Education & Research Quality

Tenure: Trustees shall serve subject to performance reviews, maintaining good standing, and continued eligibility under applicable law. The Board may co-opt additional members to enhance diversity, technical expertise, or representation, subject to CAC notification and compliance with CAMA 2020.

9.1 Chairman – Chief (Dr.) Akpobolokami Andy Mezeh

Provides strategic and visionary leadership, presides over all meetings, ensures effective governance, and represents EDF at official and inter-organisational engagements. The Chairman shall co-sign all official instruments and uphold the Foundation’s moral and ethical standing.

9.2 Vice-Chairman – Cmr. Togo Ojobokeme

Assists the Chair and acts in his absence. Oversees the Governance and Nominations Committee and liaises with government agencies, professional associations, and local communities to foster institutional synergy and compliance.

9.3 Secretary – Zenetubor Pelle Emeleakpo

Serves as custodian of the Foundation’s records, issues meeting notices, maintains statutory registers, prepares minutes, and manages correspondence with regulatory bodies such as CAC. The Secretary ensures all legal filings and resolutions are documented and stored appropriately.

9.4 Treasurer – Pastor Paddy Boye Peretu

Supervises financial operations, prepares periodic financial reports, ensures compliance with accounting standards, and oversees audits. Chairs the Finance, Audit, and Risk Committee, ensuring transparency in all financial dealings.

9.5 ICT & Compliance Officer – Cmr. Fabian Agbogidi

Leads digital transformation and ensures adherence to the Nigeria Data Protection Act (2023) and Anti-Money Laundering (AML) regulations. Oversees cybersecurity, data governance, and registration with SCUML.

9.6 Education & Research Quality – Evang. Salvation Amadi

Coordinates all academic, research, and training programmes, fostering collaboration with universities, research institutes, and NGOs. Ensures educational content and research projects meet internationally accepted standards and integrate sustainability principles.

The Board shall meet at least four times annually, and may convene extraordinary meetings as needed. A quorum shall be a simple majority of serving trustees, including either the Chair or the Vice-Chair. Decisions shall be made by consensus where possible, failing which by a majority of those present and voting; in the event of a tie, the Chair shall have a casting vote.

Meetings may be held physically or virtually, provided identity verification and record-keeping standards are met. Minutes approved by the Chair and Secretary shall constitute the official record.

Electronic signatures and filings are valid to the extent permitted under CAC rules, recognising the Commission’s automation of pre- and post-incorporation procedures (KPMG, 2021).

The Board may constitute Standing and Ad-hoc Committees to enhance effectiveness and oversight.

11.1 Standing Committees and Their Functions

Finance, Audit and Risk Committee (FARC): Chaired by the Treasurer, it oversees financial management, internal controls, audits, and risk mitigation.

Governance and Nominations Committee (GNC): Chaired by the Vice-Chairman, manages trustee recruitment, succession planning, and ethics compliance.

Programmes and Partnerships Committee (PPC): Oversees programme design, project development, and partnerships alignment with EDF’s mission.

Monitoring, Evaluation and Learning Committee (MELC): Chaired by the Secretary; supervises performance indicators, evaluation, and institutional learning.

Digital Transformation and Data Protection Committee (DDPC): Chaired by the ICT & Compliance Lead; ensures security of data systems and compliance with privacy laws.

11.2 Ad-hoc Committees

The Board may establish ad-hoc committees for specific projects or investigations, which shall automatically dissolve upon completion of their mandate.

The financial year shall run from 1 January to 31 December, consistent with prevailing CAC practice guidelines for Incorporated Trustees. EDF shall maintain accurate books of account, approve annual budgets before the start of each financial year, and subject its accounts to independent audit by a registered auditor appointed by the Board.

The Board shall ensure timely filing of bi-annual returns (for periods ending 30 June and 31 December) and the statutory annual return, together with required financial statements and trustee information, in line with CAMA 2020 and the Companies Regulations 2021 (PwC, 2021).

EDF shall operate bank accounts in reputable Nigerian banks.

The Board shall approve bank signatories and transaction thresholds.

All payments shall align with the approved budget, procurement policies, and donor conditions, with dual authorisation and segregation of duties to prevent conflicts and irregularities.

The Treasurer shall present quarterly financial reports to the Board, reporting on variances and risk mitigations.

Trustees and officers shall disclose any direct or indirect interests in transactions or decisions of EDF and shall recuse themselves from related deliberations and votes. A register of interests shall be maintained by the Secretary and updated annually. Codes of conduct, safeguarding policies for children and vulnerable persons, anti-fraud and whistle-blowing procedures, and data protection policies shall be adopted and enforced across EDF’s operations and partners. Breaches may attract sanctions up to removal from office and reporting to competent authorities.

EDF may employ staff and engage volunteers in accordance with Nigerian labour standards and its internal human resource policies. Recruitment shall be merit-based and inclusive, with equal opportunity regardless of gender, ethnicity, religion, or disability status. Volunteers shall operate under written terms, with induction and supervision aligned to programme standards.

All programmes shall have clear theories of change, logical frameworks, budgets, risk assessments, and safeguarding measures. The Secretary, as M&E Lead, shall coordinate data systems, periodic evaluations, and learning products to inform Board decisions and donor reporting.

Findings shall be disseminated to communities and partners to enhance transparency and uptake. Where relevant, programme design will integrate environmental sustainability and digital transformation to maximise reach and resilience (EDF Concept Note).

EDF may receive donations, grants, and gifts from lawful sources, subject to due diligence procedures that uphold integrity and prevent money-laundering or terrorism-financing risks.

The ICT/Compliance Lead shall coordinate SCUML registration and ongoing compliance, maintain donor due diligence records, and present compliance reports to the Finance, Audit & Risk Committee (SCUML, 2025; SCUML, 2021).

Public representations shall be authorised by the Chair or a designate.

EDF’s name, logo, and brands shall be protected from misuse. Advocacy shall be evidence-based, non-partisan, and aligned with EDF’s objectives and legal obligations.

EDF shall have a common seal kept in the custody of the Secretary and used only by authority of the Board, with impressions recorded in a register.

Documents requiring execution under seal shall be signed by two authorised trustees, including the Chair or Vice-Chair and the Secretary or Treasurer.

This Constitution may be amended by a two-thirds majority of serving trustees at a duly convened meeting, provided that the proposed amendments have been circulated at least fourteen days in advance. Where the amendment concerns fundamental objects or trustee provisions, statutory notifications and approvals shall be made to the CAC in accordance with CAMA 2020 and the Companies Regulations 2021 (Corporate Affairs Commission, 2021).

EDF may only be dissolved by a resolution passed by at least two-thirds of serving trustees at a meeting called for that purpose and, where required, subject to court order or regulatory oversight under CAMA. Upon dissolution, assets remaining after satisfaction of liabilities shall be transferred to one or more charitable organisations in Nigeria with similar objects, and in no case distributed to trustees or staff (Companies and Allied Matters Act, 2020).

In this Constitution, words importing the singular include the plural and vice-versa; “Board” means the Board of Trustees; and “CAMA” means the Companies and Allied Matters Act, 2020, including subsequent amendments and regulations.

Any matter not expressly provided for shall be determined by the Board in accordance with Nigerian law and good governance practice. This Constitution shall take effect from the date of adoption by the Board and remains in force until amended or repealed in accordance with Article 20 above.

Adopted by resolution of the Board of Trustees on the 4th day of October, 2025, and executed as follows:

Chief (Dr.) Akpobolokami Andy Mezeh – Chairman ____________________________

Cmr. Togo Ojobokeme – Vice-Chairman ______________________________________

Evang. Zenetubor Pelle Emeleakpo – Secretary ________________________________

Agbogidi Tam Fabian – ICT & Compliance ____________________________________

Pastor Paddy Boye Peretu – Treasurer _______________________________________

Evang. Salvation Amadi – Education & Research Quality ________________________

Minutes of the Inaugural Meeting of the Board of Trustees of the Esuku Development Foundation (EDF)

Held on: 4th October, 2024

Venue: Virtual Platform (WhatsApp)

Time: 8:00pm

Present:

Chief (Dr.) Akpobolokami Andy Mezeh – Chairman

Cmr. Togo Ojobokeme – Vice-Chairman

Agbogidi Tam Fabian – ICT & Compliance

Evang. Zenetubor Pelle Emeleakpo – Secretary

Pastor Paddy Boye Peretu – Treasurer

Evang. Salvation Amadi – Education & Research Quality Lead

Agenda:

Opening prayer and welcome remarks

Presentation and adoption of the draft Constitution

Appointment of officers of the Board

Adoption of governance structure and committees

Resolution for CAC registration

Mandate to open a bank account

Mandate to create a website

Any other business

Adjournment

Proceedings:

The meeting commenced with an opening prayer led by Evangelist Zenetubor Pelle Emeleakpo. Chief (Dr.) Akpobolokami Andy Mezeh, the Chairman, welcomed all members and reiterated the vision of the Foundation to empower the Niger Delta region through education, capacity development, and social transformation.

The draft Constitution of the Esuku Development Foundation (EDF) was presented by the Secretary, discussed clause by clause, and unanimously adopted. Trustees commended the legal clarity, governance provisions, and accountability framework embedded in the document.

Following this, officers were appointed by consensus in line with the Constitution:

Chief (Dr.) Akpobolokami Andy Mezeh – Chairman

Cmr. Togo Ojobokeme – Vice-Chairman

Agbogidi Tam Fabian – ICT & Compliance

Evang. Zenetubor Pelle Emeleakpo – Secretary

Pastor Paddy Boye Peretu – Treasurer

Evang. Salvation Amadi – Education & Research Quality Lead

The Chair moved a motion authorising the registration of the Esuku Development Foundation (EDF) with the Corporate Affairs Commission (CAC) under Part F of CAMA 2020 as an Incorporated Trustee body. The motion was seconded by Agbogidi Tam Fabian and carried unanimously.

It was further resolved that a bank account be opened in the name of the Foundation, with the Chairman, Treasurer, and Secretary as signatories. The signing combination shall be any two of the three.

Resolution:

That the Esuku Development Foundation (EDF) be duly registered with the Corporate Affairs Commission under Part F of CAMA 2020; that the Constitution as adopted shall serve as the governing document; that the named officers are hereby authorised to execute all relevant forms and documents; and that the Treasurer and Secretary shall coordinate all payments, publications, and compliance filings.

Adjournment:

There being no further business, the meeting adjourned at 10:00 PM with a closing prayer by Chief Isaac Elagha.

Signatories:

___________________________ Chief (Dr.) Akpobolokami Andy Mezeh (Chairman)

___________________________ Evang. Zenetubor Pelle Emeleakpo (Secretary)

A. Trustees’ Statutory Declaration of Compliance

(Pursuant to Section 825 of the Companies and Allied Matters Act, 2020)

I, Chief (Dr.) Akpobolokami Andy Mezeh, of (Akpobolokami Compound, Tamigbe Community), do hereby solemnly declare as follows:

That I am the Chairman of the proposed Esuku Development Foundation (EDF), established for charitable, educational, and community development purposes within the Federal Republic of Nigeria.

That the Foundation is being registered as an Incorporated Trustee body under Part F of the Companies and Allied Matters Act, 2020, with its principal objectives anchored on human capital development, educational advancement, social empowerment, and environmental sustainability.

That the Board of Trustees duly held its inaugural meeting on 4th October, 2025, where the Foundation’s Constitution was formally adopted, and trustees were appointed in accordance with Section 826 of CAMA 2020 (Companies and Allied Matters Act, 2020).

That all trustees, as listed below, are of sound mind, are not bankrupt, have not been convicted of any offence involving dishonesty or fraud, and have consented in writing to act as trustees of the Foundation:

Chief (Dr.) Akpobolokami Andy Mezeh – Chairman

Cmr. Togo Ojobokeme – Vice-Chairman

Agbogidi Tam Fabian – ICT & Compliance

Evang. Zenetubor Pelle Emeleakpo – Secretary — CEO StudentsBrainBoxIndex / Lecturer / Researcher, Niger Delta University, Amassoma, Bayelsa State

Pastor Paddy Boye Peretu — Treasurer — Community Developer

Evang. Salvation Amadi — Education & Research Quality — ICT Specialist

That the Constitution of the Foundation has been reviewed and found consistent with the statutory requirements for Incorporated Trustees as stipulated under CAMA 2020 and the Companies Regulations, 2021 (PwC, 2021).

That the Foundation shall operate solely for non-profit and public-benefit purposes and that no part of its income shall inure to any trustee or officer, except for legitimate reimbursements or approved remunerations for services rendered (CAC, 2021).

That all statutory notices of incorporation shall be published in accordance with Section 827 of CAMA 2020 in two national daily newspapers and one local newspaper circulating within Bayelsa State.

And I make this solemn declaration conscientiously believing the same to be true and in accordance with the provisions of the Oaths Act (Cap 333, Laws of the Federation of Nigeria, 2004).

Declared at:

This: (Day, Month, Year)

Before me:

Commissioner for Oaths / Notary Public

Signature of Declarant:

Chief (Dr.) Akpobolokami Andy Mezeh

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B. Extract of CAC Form IT01 – Trustees’ Information Summary

Name of Organisation: Esuku Development Foundation (EDF)

Registered as: Incorporated Trustees under Part F of the Companies and Allied Matters Act, 2020

Principal Address: (No. 1 Esuku Development Foundation, Tamigbe, Oziaraware Quarters, Tamigbe)

Nature of Activities: Educational Development, Humanitarian Empowerment, Digital Inclusion, and Community Service

Aims and Objectives: To promote education, empowerment, and socio-economic development in the Niger Delta Region

Trustees’ Particulars:

S/N / Name / Position / Occupation / Address / Signature

1 Chief (Dr.) Akpobolokami Andy Mezeh — Chairman

2 Cmr. Togo Ojobokeme — Vice-Chairman

3 Agbogidi Tam Fabian — ICT & Compliance Lead

4 Evang. Zenetubor Pelle Emeleakpo — Secretary — CEO StudentsBrainBoxIndex / Lecturer / Researcher, Niger Delta University, Amassoma, Bayelsa State

5 Pastor Paddy Boye Peretu — Treasurer — Community Developer

6 Evang. Salvation Amadi — Education & Research Quality — ICT Specialist

Date of Establishment: 3rd October, 2025

Proposed Corporate Colour Scheme: Navy Blue and White

Official Email Address: contact@esukuresourcecentre.org

Website: esukurci.org

PUBLIC NOTICE OF INTENTION TO REGISTER

ESUKU DEVELOPMENT FOUNDATION (EDF)

Notice is hereby given to the general public that the above-named organisation has applied to the Corporate Affairs Commission, Abuja, for registration under Part F of the Companies and Allied Matters Act, 2020, as an Incorporated Trustee body.

The following persons are the trustees of the Foundation:

Chief (Dr.) Akpobolokami Andy Mezeh

Cmr. Togo Ojobokeme

Agbogidi Tam Fabian

Evang. Zenetubor Pelle Emeleakpo

Pastor Paddy Boye Peretu

Evang. Salvation Amadi

The Aims and Objectives of the Foundation are:

To promote education, digital literacy, and research in Nigeria and beyond.

To empower individuals, families, and communities through capacity-building and social entrepreneurship.

To promote ethical leadership, youth engagement, and sustainable development.

To support environmental protection and humanitarian intervention initiatives.

Any objection to the registration of this Foundation should be forwarded within twenty-eight (28) days of this publication to the Registrar-General, Corporate Affairs Commission, Plot 420, Tigris Crescent, Maitama, Abuja.

Signed:

Chief (Dr.) Akpobolokami Andy Mezeh – Chairman

Evang. Zenetubor Pelle Emeleakpo – Secretary

1. Conflict of Interest Policy

The Esuku Development Foundation (EDF) recognises that trustees, officers, and employees owe the organisation a fiduciary duty of loyalty and integrity. In line with Sections 829–830 of the Companies and Allied Matters Act, 2020 (CAMA), every trustee is obliged to avoid situations in which personal, financial, or professional interests could conflict with those of the Foundation (Corporate Affairs Commission [CAC], 2021). A conflict of interest arises where a trustee or staff member stands to gain directly or indirectly from a decision or transaction in which the Foundation is involved.

To mitigate such risks, EDF requires all trustees, officers, and employees to disclose any real or potential conflicts of interest annually through a written declaration filed with the Secretary. During meetings, members with conflicting interests shall recuse themselves from deliberations and voting on matters related to their interests.

All disclosed interests shall be entered into a Register of Interests, which will be updated and reviewed annually by the Governance & Nominations Committee, chaired by the Vice-Chair (Cmr. Togo Ojobokeme).

Breaches of this policy, including failure to disclose or attempts to influence decisions for personal benefit, shall attract disciplinary measures ranging from a formal warning to removal from office. The purpose of this policy is to safeguard the Foundation’s integrity, enhance transparency, and ensure that all decisions are made in the best interests of the beneficiaries, not the trustees (PwC, 2021).

2. Safeguarding and Protection Policy

The Esuku Development Foundation (EDF) affirms that the protection of children, young people, and vulnerable adults is a moral and legal obligation under Nigerian law, the Child Rights Act (2003), and global safeguarding standards. The Foundation’s programmes often involve educational, empowerment, and mentorship activities, thus requiring strict compliance with safeguarding protocols (UNICEF, 2022).

All staff, volunteers, and trustees are required to act in ways that protect beneficiaries from abuse, neglect, exploitation, or harassment. The Foundation shall maintain a zero-tolerance stance towards any form of abuse and shall implement clear reporting mechanisms, confidential investigation procedures, and immediate remedial actions.

Every project and event must conduct a safeguarding risk assessment to identify and mitigate potential harms before implementation. Training on child protection, gender inclusion, and ethical conduct shall be mandatory for all project staff and volunteers.

The Education & Research Quality Lead (Evang. Salvation Amadi) shall coordinate the safeguarding function and report directly to the Board through the Chair. Regular reviews will ensure that policies remain aligned with national and international best practices (Save the Children, 2021).

3. Anti-Fraud and Whistle-Blowing Policy

As a charitable organisation that relies on donations, grants, and public trust, the Esuku Development Foundation (EDF) is committed to ensuring financial probity and accountability. Fraud, corruption, and misuse of funds are criminal offences punishable under the Criminal Code Act and the Economic and Financial Crimes Commission (Establishment) Act, 2004 (EFCC, 2023).

The Foundation shall maintain internal controls that prevent and detect fraud through segregation of duties, documented approval processes, and periodic audits. The Treasurer (Pastor Paddy Boye Peretu) shall oversee the financial integrity system in partnership with the Finance, Audit & Risk Committee.

A confidential whistle-blowing channel shall be established through which staff, partners, and beneficiaries can report suspicions of wrongdoing without fear of reprisal. All reports shall be investigated independently by the Governance Committee and, where necessary, escalated to appropriate law enforcement or regulatory agencies.

Whistle-blowers shall be protected under Nigeria’s Whistle-Blower Protection Policy (Federal Ministry of Finance, 2017). The Foundation commits to timely action on any substantiated case, while maintaining transparency in communicating outcomes to the Board and donors (Transparency International, 2021).

4. Data Protection and Privacy Policy

In compliance with the Nigeria Data Protection Regulation (NDPR), 2019, and the Nigeria Data Protection Act, 2023, the Esuku Development Foundation (EDF) upholds the right to privacy and data integrity of all persons whose information it collects, stores, or processes. Data collected during educational programmes, research, donor relations, or monitoring activities shall be used solely for legitimate organisational purposes and in line with the consent obtained from data subjects (National Information Technology Development Agency [NITDA], 2023).

The Foundation will ensure that personal information is lawfully and fairly processed; collected only for specified, explicit, and legitimate purposes; accurate and regularly updated; stored securely; and not retained longer than necessary. Access to sensitive information will be restricted to authorised personnel only, using passwords, encryption, and secure servers.

The ICT & Compliance Lead, Evang. Salvation Amadi, shall act as the Foundation’s Data Protection Officer (DPO) and coordinate annual data-protection audits, reporting outcomes to the Board. Data breaches shall be reported to the NITDA within seventy-two (72) hours of discovery, and corrective actions shall follow promptly. This policy will be reviewed biennially to align with evolving digital governance standards (KPMG, 2024).

5. Anti-Money Laundering (AML) and SCUML Compliance Framework

Pursuant to the Money Laundering (Prevention and Prohibition) Act, 2022, and the Special Control Unit Against Money Laundering (SCUML) Regulations, 2021, all NGOs are required to maintain transparent financial operations to prevent misuse of charitable funds (EFCC, 2023).

The Esuku Development Foundation (EDF), being a non-profit entity, acknowledges its legal obligation to comply with AML/CFT (Anti-Money Laundering and Counter-Terrorist Financing) frameworks.

The ICT & Compliance Lead shall coordinate registration with SCUML and ensure that donor onboarding, grant receipts, and disbursements undergo due diligence screening. All financial transactions shall be documented with traceable records, and suspicious activities shall be reported to SCUML or the EFCC as mandated by law (SCUML, 2023).

The Treasurer will collaborate with the Compliance Lead to conduct semi-annual AML audits and ensure that partners, suppliers, and donors are screened against global sanctions lists. Periodic training on AML/CFT requirements shall be conducted for trustees and staff.

The Foundation shall include AML compliance clauses in all partnership agreements and funding contracts, reinforcing its zero-tolerance policy toward financial misconduct. Through this framework, the Esuku Development Foundation (EDF) positions itself as a transparent, credible, and law-abiding development actor (United Nations Office on Drugs and Crime [UNODC], 2023).