Donor compliance crosswalk

PHIG Institutional Policy Manual · Consolidated edition, September 2026

Part of the PHIG policy framework. Download the full manual (PDF). To raise a concern: admin@accreditation.ge.

Policies 23–35 close the gaps that US Government, European Union, World Bank and EBRD due diligence would find in Policies 1–22; the table shows which policy answers each requirement. Where a grant agreement sets a stricter rule, that agreement prevails for that grant.

Requirement	US Government (2 CFR 200 and award terms)	European Union (Financial Regulation, pillar assessment)	World Bank	EBRD	PHIG policy
Code of conduct, ethics	Required	Required	Required	Required	1
Conflict of interest, including in procurement	Written standards required	Required	Required	Required	2, 21
Internal control and delegation	Required	Pillar: internal control	Required	Required	3, 22, 34
Fraud and corruption; prohibited practices	Mandatory disclosure to OIG	OLAF cooperation	Anti-Corruption Guidelines; INT	Enforcement Policy	5
Money laundering and terrorist financing	Anti-terrorism certification	Required	Required	Integrity due diligence	6, 7
Sanctions and exclusion screening	SAM, OFAC	EDES, EU sanctions	Debarment list	Ineligible entities	7
PSEAH, child safeguarding	Required	Required	ESF SEA/SH	Required	8, 9
Trafficking in persons	Required clause	—	ESF labour	Performance requirements	10
Non-discrimination, gender	Required	Required	ESF	Required	11
Drug-free workplace	Required	—	—	—	12
Whistleblower protection	Statutory protection for grantee staff	Required	Required	Required	13
Incident disclosure to funder	Timely written disclosure	Required	Required	Required	14, 15
Personal data protection	Required	Pillar: GDPR-level protection	Required	Required	16, 32
Procurement standards	Written procedures required	Pillar: procurement	Procurement Regulations	Procurement Policies and Rules	21
Financial management, audit	Audit and financial standards	Pillar: accounting, external audit	Required	Required	22
Sub-award management and monitoring	Risk assessment and monitoring required	Pillar: sub-delegation	Required	Required	23
Allowable costs, allocation, timekeeping	Cost principles; compensation documentation	Eligible costs	Required	Required	24
Travel costs	Travel cost principles	Eligible costs	Required	Required	25
Equipment and property	Property standards and inventory	Required	Required	Required	26
HR and compensation	Written personnel policies	Required	ESF labour and working conditions	Performance requirements	27
Environmental and social risk	Environmental compliance	Required	Environmental and Social Framework	Environmental and Social Policy	28
Grievance mechanism for communities	—	Recommended	ESF stakeholder engagement	Required	29
Lobbying and political activity	Anti-lobbying certification	Required neutrality	—	—	30
Record retention and access for audit	Records and access rights	Required	Inspection rights	Inspection rights	31
IT security, prohibited telecom	Prohibited telecommunications equipment	Required	—	—	32
Branding and visibility	Branding and marking plans	Visibility obligations	Acknowledgement	Acknowledgement	33
Risk management, continuity	Risk assessment	Pillar: internal control	Required	Required	34
Transparency, publication	Reporting	Publication of recipients	Access to information	Access to information	35

Amendments to existing policies

These rules apply immediately and will be folded into the stand-alone versions of each policy.

Policy 5: “Prohibited practices” also covers coercive practice (harming or threatening to influence action), collusive practice (arrangements between parties to achieve an improper purpose), obstructive practice (destroying evidence or impeding an investigation) and misuse of donor resources, as defined by the World Bank and EBRD. PHIG and its partners grant funders, their auditors and investigators full access to accounts, records and staff.
Policy 7: screening adds the EU Early Detection and Exclusion System (EDES) and the EBRD list of ineligible entities. PHIG keeps an active SAM registration and Unique Entity ID when it applies for US funds, and certifies that it does not provide material support to terrorism.
Policy 13: for US-funded work, staff of PHIG and its partners are protected under US federal whistleblower law when they report to a US agency Inspector General, Congress or other designated officials; PHIG informs staff of these rights in writing.
Policy 15: for US awards, credible evidence of fraud, bribery or gratuity violations affecting the award is disclosed in writing to the awarding agency and its Office of Inspector General. For EU grants, the European Anti-Fraud Office (OLAF) may be notified; for World Bank financing, the Integrity Vice Presidency (INT); for EBRD financing, the Office of the Chief Compliance Officer.
Policy 21: when a donor sets lower thresholds, specific procurement methods or nationality and origin rules, those rules replace PHIG’s for that grant.