This framework sets out the policies by which the Public Health Institute of Georgia (PHIG) and every platform of its network — the Georgian Medical Journal, GMJ News, GMJ Academy, the Georgian Institute of Labour Studies, Sheni Labs, SupplementIndex, SheniEkimi Certification (certificate.ge), and PHIG’s roles in Accréditation Sans Frontières and the Accreditation Canada – Georgia office — govern themselves. It is written to the standards required by the European Union (Financial Regulation, Model Grant Agreement, Horizon Europe, EU4Health, ECHO), United States federal awards (2 CFR 200, USAID ADS, PHS/NIH rules), WHO and the United Nations (FENSA, UN standards of conduct, HACT), and the bilateral and multilateral donors most active in health and humanitarian work — Global Affairs Canada, Australia’s DFAT, Japan’s JICA and MOFA, Korea’s KOICA, Norway’s Norad and MFA, Sweden’s Sida, Denmark’s Danida, Finland’s MFA, the Netherlands, Switzerland’s SDC, Germany’s BMZ/GIZ, France’s AFD and CDCS, the United Kingdom’s FCDO, Saudi KSrelief, the Global Fund, Gavi, the World Bank and the Asian Development Bank — and to the Core Humanitarian Standard. PHIG is both a public health institute and a humanitarian organisation based in Georgia, and the framework is built so that any of them can be answered with a document already in place. Each policy states the instruments it satisfies. The policies apply to all PHIG activities whether or not they are externally funded.
Status: PHIG Policy Framework, version 1.2 (seventy-five policies) — adopted by the Board of PHIG on 1 September 2026 (policies 01–15 as version 1.0, 16–50 as version 1.1, 51–75 as version 1.2, all with effect from that date); signed by the Chair, Prof. Giorgi Pkhakadze, MD, MPH, PhD. Each policy carries its own review cycle; the framework as a whole is reviewed every two years. The full set is available as a single PDF for applications and audits.
Download the full framework as PDF (v1.2, 94 pages, with charts) →
The seventy-five policies
| No. | Policy | Main references |
|---|---|---|
| 01 | Conflict of Interest Policy | Financial Regulation (EU, Euratom) 2024/2509, Art. 61; EU Model Grant Agreement Art. 12 (Conflict of interests); Horizon Europe Annotated Grant Agreement; EU Rules on Participation |
| 02 | Anti-Fraud, Anti-Corruption and Anti-Bribery Policy | Financial Regulation 2024/2509, Arts. 136–138 (exclusion) and 139; EU Model Grant Agreement Art. 11 (Fraud, corruption, irregularities) and Art. 25 (Checks, audits, OLAF/EPPO); Directive (EU) 2017/1371 (PIF Directive); Regulation (EU, Euratom) 883/2013 (OLAF) |
| 03 | Whistleblowing and Reporting of Irregularities Procedure | 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 |
| 04 | Code of Ethics and Research Integrity | ALLEA European Code of Conduct for Research Integrity (2023 revised edition); Horizon Europe Model Grant Agreement Art. 14 (Ethics and values) and Annex 5; Declaration of Helsinki; ICMJE Recommendations; COPE Core Practices |
| 05 | Data Protection and Privacy Policy | Regulation (EU) 2016/679 (GDPR); Law of Georgia on Personal Data Protection (2023); EU Model Grant Agreement Art. 15 (Data protection); Convention 108+ |
| 06 | Gender Equality Plan | Horizon Europe eligibility condition (Regulation (EU) 2021/695, Art. 22(3)); European Commission guidance “Horizon Europe Gender Equality Plans”; EU Gender Equality Strategy 2020–2025 |
| 07 | Equal Opportunities, Non-Discrimination and Anti-Harassment Policy | Charter of Fundamental Rights of the EU, Arts. 21 and 23; Directives 2000/43/EC, 2000/78/EC, 2006/54/EC; Horizon Europe MGA Art. 14 (EU values); Law of Georgia on the Elimination of All Forms of Discrimination (2014) |
| 08 | Safeguarding Policy — Children and Adults at Risk | EU Model Grant Agreement Art. 14 (ethics and values) and ethics appraisal (protection of participants); UN Convention on the Rights of the Child; Council of Europe Lanzarote Convention; EU Strategy on the Rights of the Child; Keeping Children Safe international standards |
| 09 | Environmental Sustainability Policy | European Green Deal; “do no significant harm” principle (Regulation (EU) 2020/852, Art. 17) applied in EU programmes; Horizon Europe MGA Art. 14 and 17; EU4Health Regulation (EU) 2021/522 |
| 10 | Open Access and Open Science Policy | Horizon Europe MGA Art. 17 and Annex 5 (open science: open access to publications, research data management, FAIR data); Council Conclusions on open science (2022); Plan S principles |
| 11 | Procurement Policy | EU Model Grant Agreement Art. 9.1 (Purchases: best value for money or lowest price, no conflict of interests) and Art. 9.3 (Subcontracting); Financial Regulation 2024/2509, Title VII; EU restrictive measures (sanctions) regulations |
| 12 | Financial Management and Internal Control Policy | EU Model Grant Agreement Arts. 6 (eligible costs), 20 (record-keeping), 21–22 (reporting and payments), 25 (checks and audits); Financial Regulation 2024/2509; Horizon Europe personnel-cost rules (daily rates, time records) |
| 13 | Visibility and Communication Policy for Funded Actions | EU Model Grant Agreement Art. 17 (Communication, dissemination and visibility); Regulation (EU) 2021/1060 Art. 47–50; EU emblem rules; the standard EU disclaimer |
| 14 | Volunteer and Expert Engagement Policy | EU Model Grant Agreement Art. 6.2.A (personnel costs: volunteers under the applicable unit-cost or in-kind rules); Horizon Europe volunteer-cost provisions where applicable; Council of Europe Recommendation on volunteering |
| 15 | Sanctions, Beneficial Ownership and Exclusion Compliance Policy | EU restrictive measures (Council Regulations under Art. 215 TFEU, including Regulation (EU) 833/2014 and 269/2014); Financial Regulation 2024/2509, Arts. 136–143 (exclusion, early detection); EU Model Grant Agreement Art. 11 and Annex 5; Directive (EU) 2015/849 (beneficial ownership) |
| 16 | Code of Conduct | ASF Policy 1; UN Standards of Conduct; EU MGA Art. 14 (EU values); USAID ADS 303 standard provisions (conduct); WHO FENSA due-diligence criteria |
| 17 | Delegation of Authority and Signatures | ASF Policy 3; EU MGA Art. 20 (record-keeping) and Financial Regulation sound financial management; USAID 2 CFR 200.302–303 (financial management, internal controls) |
| 18 | Gift Acceptance, Donor Due Diligence and Commercial Independence | ASF Policy 4; WHO FENSA (exclusion of tobacco and arms industries; due diligence on non-State actors); EU MGA Art. 14; UN Global Compact principles |
| 19 | Anti-Money Laundering and Counter-Terrorist Financing | ASF Policy 6; Directive (EU) 2015/849 and (EU) 2018/843; FATF Recommendation 8 (non-profit organisations); USAID anti-terrorism certification and E.O. 13224; Georgian AML law |
| 20 | Protection from Sexual Exploitation, Abuse and Harassment (PSEAH) | ASF Policy 8; UN Secretary-General’s Bulletin ST/SGB/2003/13; IASC Six Core Principles; USAID ADS 303 PSEA standard provision; EU DG ECHO and INTPA PSEAH requirements; WHO policy on preventing and addressing sexual misconduct |
| 21 | Combating Trafficking in Persons and Forced Labour | ASF Policy 10; US FAR 52.222-50 and 22 CFR 200/USAID anti-trafficking provisions; EU Directive 2011/36/EU; ILO Forced Labour Convention and Protocol; UK Modern Slavery Act principles |
| 22 | Drug- and Alcohol-Free Workplace | ASF Policy 12; US Drug-Free Workplace Act (2 CFR 182); Georgian labour law |
| 23 | Incident Reporting, Investigation and Management | ASF Policy 14; EU MGA Art. 11 and 25; USAID mandatory disclosures (2 CFR 200.113) and ADS 596; WHO contractor reporting obligations |
| 24 | Disclosure of Incidents to Donors | ASF Policy 15; 2 CFR 200.113 (mandatory disclosure of violations of federal criminal law involving fraud, bribery or gratuity); EU MGA Art. 11, 25 (information on fraud, irregularities, OLAF); WHO contract clauses |
| 25 | Safety, Security and Duty of Care | ASF Policy 17; EU MGA Art. 14 and 17; USAID ADS 303 (security); ILO Occupational Safety and Health Convention 155 |
| 26 | Editorial Independence and Publication Ethics | ASF Policy 19; COPE Core Practices; ICMJE Recommendations; WAME principles; EU MGA Art. 17 |
| 27 | Public Health Communication and Information Integrity | ASF Policy 20; WHO infodemic-management principles; EU Code of Practice on Disinformation (principles); UNESCO guidelines |
| 28 | Grants Management and Sub-Award Monitoring | ASF Policy 23; 2 CFR 200.331–333 (sub-recipient monitoring); EU MGA Art. 9.4 (financial support to third parties) and Art. 7 (consortium); Financial Regulation |
| 29 | Cost Allowability, Cost Allocation and Timekeeping | ASF Policy 24; 2 CFR 200 Subpart E (cost principles) and 200.430 (compensation, time records); EU MGA Art. 6 (eligible costs) and personnel-cost rules; Horizon Europe daily-rate method |
| 30 | Travel and Expense Policy | ASF Policy 25; 2 CFR 200.475 (travel costs) and Fly America Act for US-funded travel; EU MGA Art. 6.2.C (travel); EU/US per-diem references |
| 31 | Asset, Equipment and Property Management | ASF Policy 26; 2 CFR 200.313–314 (equipment and supplies); EU MGA Art. 6.2.C (equipment depreciation) and Art. 16 (ownership of results) |
| 32 | Human Resources, Recruitment and Staff Conduct | ASF Policy 27; Labour Code of Georgia; 2 CFR 200.430–431; EU MGA Art. 6.2.A; ILO fundamental conventions |
| 33 | Environmental and Social Safeguards for Projects | ASF Policy 28; EU “do no significant harm” (Regulation 2020/852 Art. 17); World Bank Environmental and Social Framework; USAID 22 CFR 216 (environmental procedures); IFC Performance Standards (principles) |
| 34 | Feedback, Complaints and Grievance Mechanism | ASF Policies 29 and 39; Core Humanitarian Standard commitment 5; EU MGA Art. 17; USAID accountability provisions; ISO 10002 principles |
| 35 | Lobbying, Political Activity and Advocacy | ASF Policy 30; 2 CFR 200.450 (lobbying costs unallowable) and 31 USC 1352 (Byrd Amendment certification); EU Transparency Register rules; Georgian law on non-profits |
| 36 | Records Management and Retention | ASF Policy 31; 2 CFR 200.334–338 (record retention and access); EU MGA Art. 20 (five years, three years for low-value grants); GDPR storage limitation; Georgian accounting law |
| 37 | Information Technology and Cybersecurity | ASF Policy 32; GDPR Art. 32 (security of processing); NIS2 principles; ISO/IEC 27001 controls (reference); 2 CFR 200.303 (safeguarding information) |
| 38 | Risk Management and Business Continuity | ASF Policy 34; EU MGA Art. 13 (implementation) and risk assessment practice; 2 CFR 200.303; ISO 31000 (reference) |
| 39 | Branding, Marking and Donor Visibility | ASF Policy 33; USAID ADS 320 Branding and Marking (marking plan, “from the American people”); EU visibility rules (see Policy 13); UN/WHO visibility guidelines |
| 40 | Monitoring, Evaluation, Accountability and Learning (MEAL) | ASF Policy 38; EU MGA Art. 21 (reporting) and results frameworks; USAID ADS 201 (monitoring, evaluation and learning); OECD DAC evaluation criteria |
| 41 | Partnership and Localisation | ASF Policy 40; Grand Bargain localisation commitments; EU MGA consortium rules (Art. 7); USAID localisation policy; Core Humanitarian Standard |
| 42 | Occupational Health, Safety and Staff Wellbeing | ASF Policy 42; ILO Conventions 155 and 187; Law of Georgia on Occupational Safety (2019); EU Framework Directive 89/391/EEC principles |
| 43 | Intellectual Property, Trademarks and Licensing | ASF Policy 43; EU MGA Art. 16 (ownership, protection and exploitation of results, access rights); 2 CFR 200.315 (intangible property); Berne Convention; Georgian copyright law |
| 44 | Tax Compliance and Anti-Facilitation of Tax Evasion | ASF Policy 45; Georgian Tax Code (non-profit status, grants, VAT); OECD guidance; UK Criminal Finances Act principles |
| 45 | Cash, Advances and Banking Procedures | ASF Policy 46; 2 CFR 200.305 (payment, interest on advances); EU MGA Art. 22 (payments, pre-financing); Georgian accounting law |
| 46 | Policy Development, Approval and Review | ASF Policy 47; good governance practice; EU and US expectations that policies are approved, dated, communicated and reviewed |
| 47 | Financial Conflict of Interest in Research (US PHS/NIH rule) | 42 CFR Part 50 Subpart F (Responsibility of Applicants for Promoting Objectivity in Research, PHS/NIH); 45 CFR Part 94; NIH Grants Policy Statement; complements Policy 01 |
| 48 | Research Misconduct Procedures (US PHS rule) | 42 CFR Part 93 (Public Health Service Policies on Research Misconduct, as revised 2024); complements Policy 04 (ALLEA code) |
| 49 | Human Subjects Protection and Ethics Review | Declaration of Helsinki; CIOMS International Ethical Guidelines; 45 CFR Part 46 (US Common Rule) for US-funded research; EU MGA Art. 14 and ethics appraisal; WHO Research Ethics Review Committee requirements; Georgian law on health care (research) |
| 50 | Responsible Use of Artificial Intelligence | EU Artificial Intelligence Act (Regulation (EU) 2024/1689) risk-based principles; UNESCO Recommendation on the Ethics of AI; WHO guidance on ethics and governance of AI for health (2021, 2024); COPE/ICMJE guidance on AI in publishing; US OMB M-24-10 principles |
| 51 | Governance and Board Charter | ASF Policy 36; Civil Code of Georgia (non-entrepreneurial legal entities); EU and US donor capacity assessments (organisational governance); UN HACT/PCA criteria |
| 52 | Internal Audit and Oversight | ASF Policy 37; EU MGA Art. 25; 2 CFR 200.514 (single audit principles, reference); IIA International Standards (reference); UN HACT assurance activities |
| 53 | Transparency and Public Disclosure | ASF Policy 35; International Aid Transparency Initiative (IATI) standard; EU Transparency Register; Open Government principles; Georgian law on non-profits |
| 54 | Accountability to Affected People and Communities | ASF Policy 39; Core Humanitarian Standard (CHS 2024) commitments 4–5; IASC AAP commitments; Sphere Handbook; ECHO and GAC accountability requirements |
| 55 | Child Protection Policy | Australian DFAT Child Protection Policy requirements (PSEAH and child protection minimum standards); Global Affairs Canada child protection expectations; Keeping Children Safe standards; UN CRC; complements Policy 08 (Safeguarding) and Policy 20 (PSEAH) |
| 56 | Gender-Based Violence Prevention and Response | Global Affairs Canada Feminist International Assistance Policy expectations; Sida and Norad GBV requirements; IASC GBV Guidelines (2015); Istanbul Convention; WHO guidance on GBV in health programmes; complements Policies 06, 07, 20 |
| 57 | Disability Inclusion and Accessibility | UN Convention on the Rights of Persons with Disabilities (Georgia ratified 2014); IASC Guidelines on Inclusion of Persons with Disabilities (2019); DFAT Development for All; Norad and Sida disability inclusion requirements; EU Web Accessibility Directive and WCAG 2.1 AA; Washington Group questions |
| 58 | Humanitarian Principles and Core Humanitarian Standard Commitment | Humanitarian principles of humanity, neutrality, impartiality and independence (UNGA 46/182 and 58/114); Core Humanitarian Standard (CHS 2024); Code of Conduct for the International Red Cross and Red Crescent Movement and NGOs in Disaster Relief; ECHO Humanitarian Partnership Certificate criteria; Sphere |
| 59 | Conflict Sensitivity and Do No Harm | Swiss SDC and German GIZ/BMZ conflict-sensitive programme management (CSPM) requirements; Sida and Norad do-no-harm expectations; OECD DAC fragility guidance; CDA Do No Harm framework; complements Policies 33, 54, 58 |
| 60 | Emergency Preparedness and Humanitarian Response | Sphere Handbook; WHO Emergency Response Framework; IASC Humanitarian Programme Cycle; ECHO and KSrelief response expectations; Georgian Emergency Management Service coordination |
| 61 | Beneficiary Selection, Targeting and Fair Access | CHS commitments 1–2; Sphere; ECHO and WFP targeting guidance; EU and US non-discrimination requirements; Policy 07 |
| 62 | In-Kind Contributions, Donated Goods and Medical Product Donations | WHO Guidelines for Medicine Donations (2011); WHO guidance on donations of medical devices (2011); 2 CFR 200.306 (cost sharing, in-kind valuation); EU MGA in-kind rules; Georgian customs and tax rules on humanitarian goods |
| 63 | Supplier Code of Conduct and Outsourcing | ASF outsourcing policy; Sida, Norad and Danida supplier requirements; UN Supplier Code of Conduct; OECD Guidelines for Multinational Enterprises; ILO core conventions; Policies 11, 19, 21 |
| 64 | Reserves, Financial Sustainability and Liability Management | ASF financial sustainability and liability management policy; UK Charity Commission CC19 (reserves, reference); Nordic and Canadian donor financial-health criteria; Civil Code of Georgia (liability of non-entrepreneurial entities) |
| 65 | Ethical Fundraising and Donor Relations | International Statement of Ethical Principles in Fundraising; Fundraising Regulator Code (UK, reference); Global Affairs Canada and Nordic donor expectations on fundraising integrity; GDPR for donor data; Policies 18, 53 |
| 66 | Advisory and Commissioned Services | ASF advisory services policy; ISO/IEC 17020 and 17065 impartiality principles (reference); COPE guidance on conflicts; Policies 01, 18, 26 |
| 67 | Impartiality and Independence Undertaking | ASF secretariat impartiality undertaking; ISO/IEC 17020 clause 4.1 and ISO/IEC 17065 clause 4.2 (impartiality); ISQua principles; WHO FENSA; Policies 01, 18, 26, 66 |
| 68 | Leadership Succession and Key-Person Continuity | ASF leadership succession policy; Global Affairs Canada and Norad organisational-capacity criteria; UN HACT governance questions; Policy 38 (Risk and Continuity) |
| 69 | Learning, Training and Competence | ASF personnel competence and awareness policy; CHS commitment 8; EU and US donor requirements for trained staff on fraud, safeguarding, PSEAH, data protection and ethics; ISO 9001 clause 7.2 (reference) |
| 70 | Remote Work, Flexible Working and Right to Disconnect | Labour Code of Georgia; EU Work–Life Balance Directive 2019/1158 (reference); ILO guidance on teleworking; Policies 32, 42, 37 |
| 71 | Confidentiality and Information Classification | ISO/IEC 27001 Annex A information classification (reference); GDPR; EU MGA Art. 13 (confidentiality); 2 CFR 200.303(e); Policies 05, 36, 37 |
| 72 | Social Media, Spokespersons and Crisis Communication | Policies 27, 26, 13, 39; WHO risk-communication principles; UN social-media guidelines (reference) |
| 73 | Language, Translation and Multilingual Publication | ASF language and translation policy; EU multilingualism principles; WHO multilingualism policy; CHS commitment 4 (information in accessible language) |
| 74 | Vehicle and Driver Safety | UN Road Safety Strategy; WHO Global Status Report on Road Safety; ILO duty-of-care guidance; Policy 25 |
| 75 | Programme Exit, Handover and Sustainability | OECD DAC sustainability criterion; CHS commitment 3; EU MGA and 2 CFR 200 closure requirements; Global Affairs Canada and Norad sustainability expectations |
Find a policy by theme
Integrity and conduct
- 01 Conflict of Interest Policy
- 02 Anti-Fraud, Anti-Corruption and Anti-Bribery Policy
- 03 Whistleblowing and Reporting of Irregularities Procedure
- 16 Code of Conduct
- 17 Delegation of Authority and Signatures
- 18 Gift Acceptance, Donor Due Diligence and Commercial Independence
- 19 Anti-Money Laundering and Counter-Terrorist Financing
- 67 Impartiality and Independence Undertaking
People and protection
- 07 Equal Opportunities, Non-Discrimination and Anti-Harassment Policy
- 08 Safeguarding Policy — Children and Adults at Risk
- 20 Protection from Sexual Exploitation, Abuse and Harassment (PSEAH)
- 21 Combating Trafficking in Persons and Forced Labour
- 22 Drug- and Alcohol-Free Workplace
- 55 Child Protection Policy
- 56 Gender-Based Violence Prevention and Response
- 57 Disability Inclusion and Accessibility
Research, ethics and knowledge
- 04 Code of Ethics and Research Integrity
- 10 Open Access and Open Science Policy
- 26 Editorial Independence and Publication Ethics
- 27 Public Health Communication and Information Integrity
- 43 Intellectual Property, Trademarks and Licensing
- 47 Financial Conflict of Interest in Research (US PHS/NIH rule)
- 48 Research Misconduct Procedures (US PHS rule)
- 49 Human Subjects Protection and Ethics Review
- 50 Responsible Use of Artificial Intelligence
Money and compliance
- 11 Procurement Policy
- 12 Financial Management and Internal Control Policy
- 15 Sanctions, Beneficial Ownership and Exclusion Compliance Policy
- 28 Grants Management and Sub-Award Monitoring
- 29 Cost Allowability, Cost Allocation and Timekeeping
- 30 Travel and Expense Policy
- 31 Asset, Equipment and Property Management
- 44 Tax Compliance and Anti-Facilitation of Tax Evasion
- 45 Cash, Advances and Banking Procedures
- 64 Reserves, Financial Sustainability and Liability Management
- 65 Ethical Fundraising and Donor Relations
Governance and oversight
Programmes and humanitarian work
- 33 Environmental and Social Safeguards for Projects
- 34 Feedback, Complaints and Grievance Mechanism
- 40 Monitoring, Evaluation, Accountability and Learning (MEAL)
- 41 Partnership and Localisation
- 54 Accountability to Affected People and Communities
- 58 Humanitarian Principles and Core Humanitarian Standard Commitment
- 59 Conflict Sensitivity and Do No Harm
- 60 Emergency Preparedness and Humanitarian Response
- 61 Beneficiary Selection, Targeting and Fair Access
- 62 In-Kind Contributions, Donated Goods and Medical Product Donations
- 75 Programme Exit, Handover and Sustainability
Operations and people
- 23 Incident Reporting, Investigation and Management
- 24 Disclosure of Incidents to Donors
- 25 Safety, Security and Duty of Care
- 32 Human Resources, Recruitment and Staff Conduct
- 42 Occupational Health, Safety and Staff Wellbeing
- 63 Supplier Code of Conduct and Outsourcing
- 66 Advisory and Commissioned Services
- 69 Learning, Training and Competence
- 70 Remote Work, Flexible Working and Right to Disconnect
- 71 Confidentiality and Information Classification
- 74 Vehicle and Driver Safety
Communication, data and visibility
- 05 Data Protection and Privacy Policy
- 09 Environmental Sustainability Policy
- 13 Visibility and Communication Policy for Funded Actions
- 14 Volunteer and Expert Engagement Policy
- 35 Lobbying, Political Activity and Advocacy
- 36 Records Management and Retention
- 37 Information Technology and Cybersecurity
- 39 Branding, Marking and Donor Visibility
- 72 Social Media, Spokespersons and Crisis Communication
- 73 Language, Translation and Multilingual Publication
How PHIG is organised
How to raise a concern
Forms and templates
The forms the policies refer to, as editable Word files. Download all fifteen as one zip →
| Form | Title | Used under |
|---|---|---|
| F01 | Declaration of Interests | Policies 01, 47 |
| F02 | Assignment Specific Conflict Confirmation | Policies 01 |
| F03 | Incident Report | Policies 23, 24 |
| F04 | Confidential Integrity Report Whistleblowing | Policies 03 |
| F05 | Complaint and Feedback Form | Policies 34, 54 |
| F06 | Monthly Time Sheet | Policies 29, 12 |
| F07 | Travel Request and Expense Claim | Policies 30, 25 |
| F08 | Procurement Comparison and Award Record | Policies 11, 15, 63 |
| F09 | Safeguarding and PSEAH Risk Assessment | Policies 08, 55, 20, 56 |
| F10 | Donor Partner and Supplier Due Diligence Checklist | Policies 18, 19, 15, 41 |
| F11 | Supplier and Partner Declaration | Policies 63, 21, 15, 02 |
| F12 | Policy Acknowledgement and Codes of Conduct | Policies 46, 16, 55, 20, 71 |
| F13 | In Kind Donation Acceptance Record | Policies 62, 18 |
| F14 | Grant Compliance Checklist | Policies 28, 12, 13, 39, 36 |
| F15 | Project Design Checklist safeguards and quality | Policies 33, 54, 56, 57, 59, 61, 75, 40 |
Our commitment to transparency and accountability
The Public Health Institute of Georgia is committed to transparency and accountability as a condition of its independence, not as a courtesy to donors. Every policy by which it governs itself is therefore public, in full, on this page; every form it uses is downloadable; every registration and document a funder or auditor may ask for is listed with its status; and every channel for raising a concern is open to anyone, including anonymously. Nothing on this page is “available on request” that could be published — what is marked “on request” is so only because it contains personal data, third-party confidential information or bank details. The framework is reviewed every two years and after any incident; changes are recorded in the version history below. Anyone may question any policy by writing to info@accreditation.ge; answers are given within 30 days.
Legal basis and jurisdictions
| Jurisdiction | What governs PHIG | How the framework complies |
|---|---|---|
| Georgia (governing law of PHIG) | Civil Code (non-entrepreneurial, non-commercial legal entities); Tax Code; Law on Accounting, Reporting and Auditing; Labour Code; Law on Occupational Safety (2019); Law on Personal Data Protection (2023); Law on the Elimination of All Forms of Discrimination (2014); Law on Facilitating the Suppression of Money Laundering and Terrorism Financing; Law on Grants; Law on Health Care (research); Law on Copyright; Law on Tobacco Control | Policies 51, 17, 44, 12, 32, 42, 05, 07, 19, 18, 49, 43, 16/18 (tobacco) are written against these laws; the Georgian text of a policy, where published, is authoritative for Georgian-law matters (Policy 73) |
| European Union | Financial Regulation (EU, Euratom) 2024/2509; EU Model Grant Agreement; Horizon Europe Regulation 2021/695; EU4Health Regulation 2021/522; GDPR 2016/679; Whistleblower Directive 2019/1937; PIF Directive 2017/1371; AML Directives; Anti-Trafficking Directive 2011/36; Taxonomy Regulation 2020/852 Art. 17 (DNSH); AI Act 2024/1689; restrictive-measures regulations; Charter of Fundamental Rights | Each policy cites the article it satisfies; the donor map above indexes them; GDPR is applied wherever EU persons’ data or EU funds are involved |
| United States | 2 CFR 200 (Uniform Guidance); 2 CFR 182 (drug-free workplace); 22 CFR 216 (environment); 42 CFR 50 Subpart F (FCOI); 42 CFR 93 (research misconduct); 45 CFR 46 (human subjects); FAR 52.222-50 (trafficking); 31 USC 1352 (lobbying); E.O. 13224 and OFAC regulations; USAID ADS 201, 303, 320; Fly America Act | Policies 12, 22, 29, 30, 31, 33, 35, 36, 39, 47, 48, 49, 19, 21 implement them; certifications are signed per award (Form F11 and the declarations listed under documents) |
| WHO and United Nations | WHO Framework of Engagement with Non-State Actors (FENSA); WHO FCTC Article 5.3; UN Standards of Conduct; ST/SGB/2003/13 (PSEA); UN Supplier Code of Conduct; HACT framework; IASC guidelines; Core Humanitarian Standard; UN sanctions | Policies 18, 16, 20, 55, 58, 54, 63, 15, 52; the tobacco and arms exclusions are absolute |
| France (through ASF) | Loi du 1er juillet 1901; French and EU rules applying to Accréditation Sans Frontières | ASF’s own 47-policy framework governs ASF; see “Sister framework” below |
Version history and review
| Version | Date | Change | Approved by |
|---|---|---|---|
| 1.0 | 1 September 2026 | First adoption of policies 01–15 | Board of PHIG |
| 1.1 | 1 September 2026 | Policies 16–50 (ASF-equivalent set; US PHS/NIH, human-subjects and AI policies); donor map; registrations | Board of PHIG |
| 1.2 | 1 September 2026 | Policies 51–75 (governance charter, internal audit, transparency, AAP, child protection, GBV, disability, humanitarian principles, conflict sensitivity, emergency response and others); organisational chart; concern flowchart; forms F01–F15 | Board of PHIG |
Last reviewed: 6 October 2026 (editorial audit of all pages, downloads and links). Next scheduled review: 1 September 2028, or earlier after any incident or change in law or donor rules (Policy 46).
What each donor asks for — and where it is
| Requirement | EU (Financial Regulation, MGA, Horizon Europe) | US (2 CFR 200, USAID, NIH/PHS) | WHO / UN | PHIG policy |
|---|---|---|---|---|
| Code of conduct, EU/UN values | MGA Art. 14 | ADS 303 standard provisions | UN standards of conduct; FENSA | 16, 07, 20 |
| Conflict of interest | FR Art. 61; MGA Art. 12 | 2 CFR 200.112, 200.318; 42 CFR 50 Subpart F for PHS research | FENSA declarations | 01, 47 |
| Fraud, corruption, bribery; mandatory disclosure | MGA Art. 11, 25; PIF Directive | 2 CFR 200.113; FAR 52.203-13 | WHO/UN anti-fraud clauses | 02, 23, 24 |
| Whistleblower protection | Directive 2019/1937 | 41 USC 4712 | UN whistleblower policy | 03 |
| Research integrity and misconduct | ALLEA code; MGA Art. 14 | 42 CFR 93 | WHO research standards | 04, 48 |
| Human subjects / ethics review | MGA Art. 14, ethics appraisal | 45 CFR 46; FWA; IRB | WHO ERC | 49 |
| Data protection and security | GDPR; MGA Art. 15 | 2 CFR 200.303(e); HIPAA where applicable | UN personal data principles | 05, 37 |
| Gender equality; non-discrimination | Horizon Europe GEP eligibility; Charter | 2 CFR 200.300; Title VI/IX principles | UN gender policies | 06, 07 |
| Safeguarding; PSEAH; trafficking; drug-free workplace | DG INTPA/ECHO PSEAH; MGA Art. 14 | ADS 303 PSEA; FAR 52.222-50; 2 CFR 182 | ST/SGB/2003/13; IASC | 08, 20, 21, 22 |
| Environment; do no significant harm | Reg. 2020/852 Art. 17 | 22 CFR 216 | UN environmental policies | 09, 33 |
| Open access, data management, IP | MGA Art. 16–17; Annex 5 | 2 CFR 200.315; NIH DMS policy | WHO open access policy | 10, 43 |
| Procurement; sanctions; AML | MGA Art. 9; FR Arts. 136–143; restrictive measures | 2 CFR 200.317–327; SAM exclusions; OFAC; anti-terrorism certification | UNGM; UN sanctions | 11, 15, 19 |
| Financial management, cost principles, timekeeping, indirect costs | MGA Art. 6, 20–22; daily rates | 2 CFR 200 Subpart E; 200.430; NICRA/de minimis | WHO DFC and contract financial rules | 12, 29, 45, 17 |
| Grants and sub-award management; records | MGA Art. 9.4, 20 | 2 CFR 200.331–333, 334–338 | UN implementing-partner rules | 28, 36 |
| Visibility, branding and marking | MGA Art. 17; emblem rules | ADS 320 | WHO/UN visibility | 13, 39 |
| Travel | MGA Art. 6.2.C | 2 CFR 200.475; Fly America | UN DSA rates | 30 |
| Equipment and assets | MGA Art. 6.2.C | 2 CFR 200.313–314 | UN asset rules | 31 |
| Lobbying restrictions | Transparency Register | 2 CFR 200.450; Byrd certification | — | 35 |
| Monitoring and evaluation; accountability to affected people | MGA Art. 21 | ADS 201 | WHO results framework; CHS | 40, 34, 41 |
| Governance, delegation, risk, continuity, HR, OSH, tax, policy management | Sound financial management | 2 CFR 200.302–303 | Due-diligence assessments (HACT/PCA) | 17, 32, 38, 42, 44, 46 |
| Independence from industry (tobacco, arms); donor due diligence | MGA Art. 14 | — | FENSA exclusions | 18, 16 |
| Editorial independence; information integrity; AI | EU AI Act principles | OMB AI guidance (reference) | WHO AI ethics guidance; infodemic management | 26, 27, 50 |
| Governance charter; internal audit; transparency; succession | Financial capacity and operational capacity checks | Pre-award survey (NUPAS); 2 CFR 200.206 | HACT micro-assessment; PCA | 51, 52, 53, 68 |
| Child protection (stand-alone) | DG INTPA/ECHO | USAID child safeguarding | UNICEF PSEA/child safeguarding | 55 (DFAT, GAC) |
| Gender-based violence; disability inclusion | EU Gender Action Plan III; Disability Strategy | USAID GBV strategy; disability policy | IASC GBV and disability guidelines | 56, 57 (GAC, Sida, Norad, DFAT) |
| Humanitarian principles; CHS; conflict sensitivity; emergency response; accountability to affected people | ECHO Humanitarian Partnership Certificate | BHA (USAID humanitarian) requirements | IASC; OCHA; Sphere | 58, 59, 60, 54 (ECHO, KSrelief, SDC, GIZ, Sida, Norad, GAC) |
| Supplier code; reserves; fundraising ethics; in-kind and medicine donations | MGA Art. 9; cost-sharing rules | 2 CFR 200.306, 200.318 | UN Supplier Code; WHO medicine-donation guidelines | 63, 64, 65, 62 (Nordic and Canadian donors) |
| Beneficiary selection; programme exit and sustainability | OECD DAC criteria | ADS 201 | CHS 1–3 | 61, 75 |
| Impartiality; advisory services; confidentiality; social media; language; remote work; vehicles; training | ISO 17020/17065 principles; MGA Art. 13 | 2 CFR 200.303 | UN guidelines | 66, 67, 71, 72, 73, 70, 74, 69 |
Registrations and certifications held or required
| Registration | Needed for | Status |
|---|---|---|
| Public Registry of Georgia — non-entrepreneurial (non-commercial) legal entity | All | Held; registration number on request |
| EU Funding & Tenders Portal — Participant Identification Code (PIC), legal entity validation, LEAR, bank validation | EU grants (Horizon Europe, EU4Health, Erasmus+, EU Delegation calls) | Registration in progress |
| EU Transparency Register | Engagement with EU institutions | Planned (see Legal status) |
| SAM.gov registration with Unique Entity ID (UEI); NCAGE code | US federal awards (USAID, NIH, CDC, State) | Registration in progress |
| Negotiated indirect cost rate (NICRA) or de minimis election | US awards | De minimis rate elected until a NICRA is negotiated |
| Federalwide Assurance (FWA) and IRB access | US-funded human-subjects research | Through David Tvildiani Medical University; FWA to be obtained when required |
| UN Global Marketplace (UNGM) vendor registration | WHO/UN contracts | Registration in progress |
| UN Partner Portal | UNHCR/UNICEF/WFP partnerships | To be completed when a partnership is proposed |
| WHO FENSA due diligence (non-State actor) | Official relations and collaboration with WHO | See Legal status and international standing |
| Crossref membership #56297; ORCID; DOI prefix 10.66636 | Publishing | Held |
| Audited financial statements (last two years) | EU financial capacity; US pre-award survey; UN HACT micro-assessment | Prepared annually; available on request |
| Statutes and registration extract with certified English translation | All | Available on request |
Organisational documents (available on request to donors and auditors)
| Document | Status |
|---|---|
| Statutes (charter) of PHIG, Georgian original and certified English translation | Held |
| Extract from the Public Registry of Georgia (registration, legal representative) | Held |
| List of Board members with roles, terms and declarations of interest | Held; published |
| Organisational chart (Board, committees, Director, platforms, functions) | Held; published on the About page |
| Annual report and summary accounts | First full-year report (2026) due 30 June 2027; earlier years on request |
| Audited financial statements, last two years | On request |
| Bank letter / proof of account; tax registration certificate | On request |
| Strategic plan | Published (Strategy page) |
| Risk register; business continuity plan; succession register | Held |
| Salary scale; staff list; sample contracts and time sheets | On request |
| Chart of accounts and cost-allocation method | On request |
| Procurement thresholds and templates; supplier code of conduct | Policies 11, 63 |
| Declarations: honour (EU), anti-terrorism and Byrd (US), FENSA (WHO), CHS self-assessment | Signed per application |
| Training records; signed codes of conduct | Held |
| Insurance certificates | On request |
| Data processing register; privacy notices | Held |
| Evaluation reports; methods of each platform | Published |
Sister framework: Accréditation Sans Frontières
Accréditation Sans Frontières (ASF), PHIG’s international accreditation partner registered in Paris, is a separate legal entity with its own policy framework of 75 policies (every ASF policy has a counterpart here) at france-asf.fr/about/policies. The two frameworks are aligned in substance and numbered differently; each policy of this framework cites the corresponding ASF policy. They are maintained separately because each organisation is accountable under its own law (Georgian law for PHIG, French association law for ASF). Where PHIG acts for ASF in Georgia, ASF’s policies apply to that work; where ASF relies on PHIG’s platforms, this framework applies. Conflicts are resolved by the stricter rule.
Related statements
Legal status and international standing · Financial sustainability · Support PHIG (including the firm line on the tobacco industry) · Sheni Labs methodology.
All correspondence — general enquiries, integrity reports (subject line “Confidential — integrity”) and data-protection requests — goes to info@accreditation.ge; matters for the Chair personally to giorgi.pkhakadze@accreditation.ge.