PHIG Policy Framework v1.2 · Policy 15 · Adopted 1 September 2026 · References: 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)
1. Purpose
To ensure that PHIG, its Board, its beneficial owners (there are none, PHIG being a non-profit with no shareholders), its partners, subcontractors, suppliers and recipients of its funds are not subject to EU, UN or other applicable sanctions, are not excluded from EU funding, and that PHIG can declare this truthfully in every application and grant agreement.
2. Declarations PHIG makes
- PHIG is a non-profit legal entity with no shareholders and no beneficial owners in the sense of Directive (EU) 2015/849; its governing body is its Board, whose members are listed in the Public Registry of Georgia and on publichealth.ge.
- Neither PHIG nor any Board member or person with powers of representation, decision or control is: bankrupt; in breach of tax or social-security obligations; guilty of grave professional misconduct; convicted of fraud, corruption, participation in a criminal organisation, money laundering, terrorist financing or child labour; subject to EU sanctions; or listed in the EU early-detection and exclusion system — the grounds of Article 136 of the Financial Regulation.
- PHIG makes this declaration of honour in every EU application and informs the granting authority of any change.
3. Checks PHIG performs
- Before engaging any partner, subcontractor, supplier, sub-grantee or recipient of funds above EUR 1,000, PHIG checks the entity and its known owners and managers against the EU consolidated sanctions list, the UN consolidated list and, where relevant, OFAC and UK lists; the result is recorded in the procurement or partnership file.
- Partners in EU-funded consortia provide their own declaration of honour; PHIG keeps copies.
- Checks are repeated annually for ongoing relationships and at each payment above EUR 10,000.
- No funds are transferred to sanctioned persons or entities, to entities in sanctioned territories where the measures prohibit it, or to entities that cannot identify their beneficial owners.
4. Related-party transactions
Any contract or payment between PHIG and an entity in which a Board member, the Director, a staff member or their close family has an interest (including Accréditation Sans Frontières, Sheni-branded companies and the Georgian Medical Journal’s publishing operations) is disclosed under the Conflict of Interest Policy, approved by the Board without the interested person, concluded at arm’s length, and listed in the annual summary.
5. Responsibilities
Director: declarations and checks. Finance function: payment screening. Board: approval of related-party transactions and annual review of this policy.
6. Review
Annually and when sanctions regimes change.
Part of the PHIG Policy Framework. Breaches and concerns may be reported under the Whistleblowing Procedure to info@accreditation.ge (subject “Confidential — integrity”).