Part of the ASF policy framework, aligned with the equivalent PHIG policy. To raise a concern: see the ASF Complaints and Reporting Channel.
ASF tells affected donors about credible incidents promptly and fully, within the timelines below or any shorter timeline in the funding agreement. Owner: Operations Liaison.
When to disclose
A disclosure is required when an allegation is credible — supported by enough information to justify investigation — and it involves donor funds, donor-funded personnel or partners, or participants in a donor-funded project. ASF does not wait for the investigation to finish.
Timelines
| Incident | Initial notice to donor | Updates | Final report |
|---|---|---|---|
| Sanctions or prohibited-party match | Within 2 working days | As agreed | Within 5 working days of confirmation |
| Sexual exploitation, abuse or child abuse | Within 3 working days (without identifying the survivor) | Every 30 days | Within 10 working days of closure |
| Fraud, bribery, corruption, money laundering, trafficking | Within 5 working days | Every 30 days | Within 10 working days of closure |
| Serious security incident affecting a funded activity | Within 24 hours | As needed | Within 10 working days |
| Data breach involving donor-funded project data | Within 72 hours | As needed | Within 10 working days of closure |
| Other misconduct affecting donor funds | Within 10 working days | Quarterly | Within 10 working days of closure |
Content of a disclosure
- Date reported and date of the incident; category; project and funding affected.
- Estimated value at risk, if financial.
- Immediate actions taken to protect people and funds.
- Investigation plan and expected timeline.
- No names of survivors, witnesses or reporters, and no information that could identify them.
Approval and record
The Ethics and Compliance Officer drafts; the Operations Liaison signs; the Chair is copied. If the Operations Liaison is implicated, the Chair signs. Every disclosure and donor reply is filed in the incident register. Semi-annual summaries of all incidents are shared with donors that require them.