PHIG Policy Framework v1.2 · Policy 28 · Adopted 1 September 2026 · References: 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
1. Purpose and scope
To manage grants received and funds passed on to partners and sub-grantees so that every obligation to the donor is met and flowed down. Applies to the Board, the Director, staff, consultants, volunteers, experts, partners and suppliers of PHIG and all platforms of its network.
2. Policy
- Each grant has a lead, a budget in PHIG’s cost centres, a compliance checklist of the agreement’s obligations (reporting, visibility, ethics, procurement, audit rights, retention), a calendar of deadlines, and a risk assessment.
- Reports — narrative and financial — are prepared from the accounting and project records, reviewed by the Director and submitted on time; requests for amendments are made in advance.
- Sub-awards and financial support to third parties are made only where the grant allows, by written agreement that flows down all relevant obligations (eligibility, audit, visibility, PSEAH, anti-trafficking, sanctions, data protection), after due diligence on the recipient’s capacity and integrity.
- Sub-recipients are monitored proportionately: reports, document checks, site visits for higher-risk or larger awards; findings followed up; funds recovered where misused.
- Closure: final reports, reconciliation, asset disposition per the grant, retention of records (five years EU; three years US after final report, longer if audits are open).
3. Procedures
- Grant file template; sub-award agreement template; monitoring plan.
Responsibilities
Director; project leads; accountant.
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”).