PHIG Policy Framework v1.2 · Policy 02 · Adopted 1 September 2026 · References: 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)
1. Purpose
PHIG tolerates no fraud, corruption, bribery or misuse of funds, whether its own, donors’ or the European Union’s. This policy defines those terms, commits the institute to prevention, detection and reporting, and sets out what every person must do.
2. Scope
All persons acting for PHIG and its network (as defined in the Conflict of Interest Policy), all partners, subcontractors and suppliers engaged by PHIG, and all funds received or managed by PHIG, including EU funds.
3. Definitions
- Fraud: any intentional act or omission relating to the use or presentation of false, incorrect or incomplete statements or documents, non-disclosure of information in violation of a specific obligation, or misapplication of funds or assets for purposes other than those for which they were granted — as defined in Directive (EU) 2017/1371.
- Corruption: the abuse of entrusted power for private gain; active corruption (offering or giving an undue advantage to influence an official) and passive corruption (requesting or accepting one).
- Bribery: offering, promising, giving, requesting or accepting any undue advantage to induce improper performance of a function.
- Irregularity: any infringement of a provision of applicable law, a grant agreement or this policy resulting from an act or omission that has, or would have, the effect of prejudicing a budget, by an unjustified item of expenditure.
- Facilitation payment: a small payment to secure or expedite a routine action; prohibited.
4. Policy
- No person acting for PHIG offers, gives, requests or accepts any bribe, kickback, facilitation payment or undue advantage, directly or through intermediaries, in any country.
- No person falsifies, inflates or misrepresents costs, timesheets, deliverables, results or documents, and none submits a claim for costs that are not real, incurred, necessary and recorded.
- PHIG keeps complete and accurate books and records, in line with the Financial Management Policy, so that every transaction can be traced to its purpose and authorisation.
- PHIG assesses fraud risk for each programme and each grant at the planning stage and applies proportionate controls: segregation of duties, dual authorisation of payments, independent verification of deliverables, procurement rules, and random checks.
- Suspected fraud, corruption or irregularity is reported immediately through the Whistleblowing Procedure; the person reporting in good faith is protected from retaliation.
- PHIG cooperates fully with investigations by donors, the European Anti-Fraud Office (OLAF), the European Public Prosecutor’s Office (EPPO), the European Court of Auditors and national authorities, and grants them access to premises, records and persons as required by the grant agreement.
- Confirmed fraud or corruption is reported to the granting authority and, where the law requires, to the police or prosecutor; amounts unduly received are recovered; contracts are terminated; the person is excluded from any future role.
- PHIG does not engage any partner, subcontractor or supplier that is excluded from EU funding or appears on EU, UN or other applicable sanctions lists, and checks this before contracting (see Sanctions Compliance in the Procurement Policy).
5. Responsibilities
- Board: adopts the policy, receives an annual fraud-risk report, decides on cases involving the Director.
- Director: implements controls, receives reports, leads investigations, reports to donors.
- Finance function (accountant): maintains records, applies dual authorisation, flags anomalies.
- Everyone: refuses, records, reports.
6. Procedure for suspected cases
- Report received (Whistleblowing Procedure) and logged within two working days.
- Preliminary assessment by the Director (or a Board member if the Director is concerned) within ten working days; evidence secured.
- Investigation by a person without conflict; the person concerned is heard; findings documented.
- Decision: no case, corrective action, sanction, recovery, referral to authorities, report to donor — recorded and, where EU funds are concerned, notified to the granting authority.
- Lessons recorded; controls adjusted.
7. Training and awareness
Every person with financial or decision-making responsibility receives this policy on joining and confirms in writing that they have read it; grant teams are briefed on the fraud provisions of each grant agreement.
8. Review
Reviewed every two years, after any confirmed case, and whenever EU rules change.
Part of the PHIG Policy Framework. Breaches and concerns may be reported under the Whistleblowing Procedure to info@accreditation.ge (subject “Confidential — integrity”).