PHIG Policy Framework v1.2 · Policy 11 · Adopted 1 September 2026 · References: 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
1. Purpose
To ensure that PHIG buys goods, services and works on the basis of best value for money or, where appropriate, lowest price; that there is no conflict of interest; that EU and donor rules are met; and that the process can be audited.
2. Principles
Economy, efficiency, effectiveness · equal treatment and non-discrimination · transparency · proportionality · sound financial management · no conflict of interest · compliance with sanctions and exclusion rules · environmental and social responsibility.
3. Thresholds and procedures (EUR, excluding VAT)
| Value | Procedure | Record |
|---|---|---|
| Up to 2,500 | Direct purchase from a suitable supplier at a reasonable price | Invoice and justification note |
| 2,501 – 15,000 | At least three written quotations; selection on best value for money | Request, quotations, comparison table, decision |
| 15,001 – 60,000 | Written call for offers sent to at least five suppliers or published; evaluation by two persons against pre-set criteria | Call, offers, evaluation report, contract |
| Above 60,000 | Open published tender with a published evaluation grid; evaluation committee of three | Full tender file |
Where a donor’s rules set lower thresholds or specific procedures, those apply. Contracts are not split to stay under a threshold.
4. Rules
- Specifications are written before suppliers are approached and do not favour a brand or supplier.
- Evaluation criteria and their weights are set in advance; price is always one of them.
- Evaluators sign a declaration of no conflict of interest for each procedure.
- Suppliers are checked against EU and UN sanctions lists and the EU early-detection and exclusion system before contracting; excluded or sanctioned parties are not engaged.
- Contracts are in writing and state deliverables, price, deadlines, intellectual property, data protection, audit rights of PHIG and donors (including OLAF, EPPO and the European Court of Auditors for EU funds), and termination.
- Subcontracting in EU-funded actions is limited to tasks foreseen in the grant, awarded on best value, and does not cover core project tasks.
- Environmental and social criteria are included where relevant.
- No gifts or hospitality from suppliers beyond negligible value.
- All records are retained for five years after the final payment of the grant concerned, or longer if the donor requires.
5. Responsibilities
The Director authorises purchases; the finance function checks compliance before payment; the Board approves contracts above EUR 60,000 and any contract with a related party.
6. 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”).