PHIG Policy Framework v1.2 · Policy 24 · Adopted 1 September 2026 · References: 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
1. Purpose and scope
To ensure that donors are informed promptly and accurately of incidents affecting their funds, in line with their rules, and that PHIG never conceals an irregularity. Applies to the Board, the Director, staff, consultants, volunteers, experts, partners and suppliers of PHIG and all platforms of its network.
2. Policy
- PHIG discloses in writing to the granting authority, within the time its rules require and in any case within ten working days, any credible evidence of fraud, corruption, bribery, conflict of interest, serious irregularity, misuse of funds, sanctions breach, trafficking, PSEAH or safeguarding incident, data breach involving the action, or significant loss, connected with that donor’s funds.
- Disclosure is made by the Director after informing the Chair; it states the facts known, the action taken, and the planned investigation; updates follow.
- Disclosure does not wait for the end of an investigation when the donor’s rules require earlier notice (e.g., USAID: immediately for trafficking and PSEAH; mandatory disclosure of criminal violations).
- Records of disclosures are kept in the incident register.
Responsibilities
Director; Chair; Board informed.
Review
Every two years and when donor 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”).