PHIG Policy Framework v1.2 · Policy 03 · Adopted 1 September 2026 · References: Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law; EU Model Grant Agreement Art. 11 and 25; Financial Regulation 2024/2509
1. Purpose
To give every person a safe, confidential channel to report wrongdoing at PHIG or in its network — fraud, corruption, conflict of interest, harassment, safeguarding concerns, research misconduct, breaches of data protection, danger to health or safety, misuse of funds, or any breach of law or PHIG policy — and to protect those who report in good faith from retaliation, in line with Directive (EU) 2019/1937.
2. Who may report
Board members, staff, consultants, volunteers, experts, reviewers, authors, students, partners, suppliers, beneficiaries and members of the public. Reports may be made by current and former persons, and by applicants and candidates.
3. What may be reported
Any reasonable suspicion of wrongdoing listed above. The reporter need not have proof; a reasonable belief, held in good faith, is enough. Knowingly false reports are themselves misconduct.
4. Channels
- Internal channel: a dedicated address, info@accreditation.ge, marked “Confidential — integrity” in the subject line, opened only by the designated Integrity Officer (a Board member who is not the Director); or in writing to the Integrity Officer at PHIG’s registered office marked “Confidential — integrity”.
- Where the Integrity Officer is concerned: directly to the Chair of the Board at giorgi.pkhakadze@accreditation.ge, or, if the Chair is concerned, to any other Board member in writing at the registered office.
- External channels: for breaches concerning EU funds, the European Anti-Fraud Office (OLAF) and the European Public Prosecutor’s Office (EPPO); for other matters, the competent Georgian authorities. The reporter may use an external channel directly, without using the internal one first, and retains protection.
- Anonymous reports are accepted and followed up as far as the information allows.
5. Handling
- Acknowledgement within seven days of receipt.
- Assessment and, where warranted, investigation by a person free of conflict; the identity of the reporter is disclosed only with their consent or where the law requires.
- Feedback to the reporter within three months of acknowledgement on the action taken or planned.
- Records kept securely, separately from personnel files, for the time needed and no longer than five years after closure unless legal proceedings require more.
6. Protection against retaliation
No dismissal, demotion, loss of assignment, exclusion from a pool or committee, withdrawal of a review, negative reference, harassment, blacklisting or any other detriment may be imposed on a person for reporting in good faith, for supporting a reporter, or for being related to one. Any retaliation is itself a serious breach dealt with under the Anti-Fraud Policy and the Equal Opportunities Policy. A person who suffers retaliation may report it to the Board and to the competent authority.
7. Rights of the person reported
Presumption of good faith until findings are made; information about the allegation at the appropriate stage; the opportunity to respond; confidentiality; protection of personal data under the Data Protection Policy.
8. Responsibilities
- Integrity Officer: receives, logs, assesses, assigns investigations, reports to the Board quarterly in anonymised form.
- Board: appoints the Integrity Officer, decides cases involving the Director, reviews the procedure.
- Director: ensures the channel is publicised on every site of the network and known to every person within scope.
9. Review
Reviewed every two years and after any case that reveals a weakness.
Part of the PHIG Policy Framework. Breaches and concerns may be reported under the Whistleblowing Procedure to info@accreditation.ge (subject “Confidential — integrity”).