About ASF · Governance
Donor Compliance Crosswalk
Which ASF policy answers each requirement a US Government, European Union, World Bank, or EBRD due-diligence review would look for — published so any prospective funder can verify compliance before asking.
Why this exists: ASF intends to apply for institutional funding from major donors. Rather than answer the same due-diligence questionnaire from scratch for each one, this page maps standard donor requirements directly to the policy that already satisfies them — and is honest about the handful of areas that would need strengthening for a specific award.
ASF Institutional Policy Manual · Aligned with ASF, September 2026
Part of the ASF Policy framework. Download the full manual (PDF). To raise a concern: info@accreditation.ge.
Policies 23–35 close the gaps that US Government, European Union, World Bank and EBRD due diligence would find in Policies 1–22; the table shows which policy answers each requirement. Where a grant agreement sets a stricter rule, that agreement prevails for that grant.
| Requirement | US Government (2 CFR 200 and award terms) | European Union (Financial Regulation, pillar assessment) | World Bank | EBRD | ASF Policy |
|---|---|---|---|---|---|
| Code of conduct, ethics | Required | Required | Required | Required | 1 |
| Conflict of interest, including in procurement | Written standards required | Required | Required | Required | 2, 21 |
| Internal control and delegation | Required | Pillar: internal control | Required | Required | 3, 22, 34 |
| Fraud and corruption; prohibited practices | Mandatory disclosure to OIG | OLAF cooperation | Anti-Corruption Guidelines; INT | Enforcement Policy | 5 |
| Money laundering and terrorist financing | Anti-terrorism certification | Required | Required | Integrity due diligence | 6, 7 |
| Sanctions and exclusion screening | SAM, OFAC | EDES, EU sanctions | Debarment list | Ineligible entities | 7 |
| PSEAH, child safeguarding | Required | Required | ESF SEA/SH | Required | 8, 9 |
| Trafficking in persons | Required clause | — | ESF labour | Performance requirements | 10 |
| Non-discrimination, gender | Required | Required | ESF | Required | 11 |
| Drug-free workplace | Required | — | — | — | 12 |
| Whistleblower protection | Statutory protection for grantee staff | Required | Required | Required | 13 |
| Incident disclosure to funder | Timely written disclosure | Required | Required | Required | 14, 15 |
| Personal data protection | Required | Pillar: GDPR-level protection | Required | Required | 16, 32 |
| Procurement standards | Written procedures required | Pillar: procurement | Procurement Regulations | Procurement Policies and Rules | 21 |
| Financial management, audit | Audit and financial standards | Pillar: accounting, external audit | Required | Required | 22 |
| Sub-award management and monitoring | Risk assessment and monitoring required | Pillar: sub-delegation | Required | Required | 23 |
| Allowable costs, allocation, timekeeping | Cost principles; compensation documentation | Eligible costs | Required | Required | 24 |
| Travel costs | Travel cost principles | Eligible costs | Required | Required | 25 |
| Equipment and property | Property standards and inventory | Required | Required | Required | 26 |
| HR and compensation | Written personnel policies | Required | ESF labour and working conditions | Performance requirements | 27 |
| Environmental and social risk | Environmental compliance | Required | Environmental and Social Framework | Environmental and Social Policy | 28 |
| Grievance mechanism for communities | — | Recommended | ESF stakeholder engagement | Required | 29 |
| Lobbying and political activity | Anti-lobbying certification | Required neutrality | — | — | 30 |
| Record retention and access for audit | Records and access rights | Required | Inspection rights | Inspection rights | 31 |
| IT security, prohibited telecom | Prohibited telecommunications equipment | Required | — | — | 32 |
| Branding and visibility | Branding and marking plans | Visibility obligations | Acknowledgement | Acknowledgement | 33 |
| Risk management, continuity | Risk assessment | Pillar: internal control | Required | Required | 34 |
| Transparency, publication | Reporting | Publication of recipients | Access to information | Access to information | 35 |
Amendments to existing policies
These rules apply immediately and will be folded into the stand-alone versions of each policy.
- Policy 5: “Prohibited practices” also covers coercive practice (harming or threatening to influence action), collusive practice (arrangements between parties to achieve an improper purpose), obstructive practice (destroying evidence or impeding an investigation) and misuse of donor resources, as defined by the World Bank and EBRD. ASF and its partners grant funders, their auditors and investigators full access to accounts, records and staff.
- Policy 7: screening adds the EU Early Detection and Exclusion System (EDES) and the EBRD list of ineligible entities. ASF keeps an active SAM registration and Unique Entity ID when it applies for US funds, and certifies that it does not provide material support to terrorism.
- Policy 13: for US-funded work, staff of ASF and its partners are protected under US federal whistleblower law when they report to a US agency Inspector General, Congress or other designated officials; ASF informs staff of these rights in writing.
- Policy 15: for US awards, credible evidence of fraud, bribery or gratuity violations affecting the award is disclosed in writing to the awarding agency and its Office of Inspector General. For EU grants, the European Anti-Fraud Office (OLAF) may be notified; for World Bank financing, the Integrity Vice Presidency (INT); for EBRD financing, the Office of the Chief Compliance Officer.
- Policy 21: when a donor sets lower thresholds, specific procurement methods or nationality and origin rules, those rules replace ASF’s for that grant.