Anti-Fraud, Bribery and Corruption
As a French association, ASF’s anti-corruption obligations are grounded in Loi Sapin II (Loi n° 2016-1691), in addition to any donor-specific anti-corruption requirement. ASF has zero tolerance for fraud, bribery and corruption by anyone acting for it — Council members, Secretariat staff, Coordinators or Monitors — and every suspicion is reported within 24 hours. Owner: ASF Secretariat, reporting to the International Standards Council.
Definitions
- Fraud: knowingly making a false or misleading representation, or hiding information, to gain an advantage — including falsifying a Monitor verification or Coordinator evidence file.
- Bribery: offering, giving, requesting or accepting anything of value to influence an accreditation decision.
- Corruption: abuse of an ASF role for private gain.
Prevention and response
Prevention runs through the structural separation already built into ASF-MON-STD-v1 (Coordinator/Monitor dual-role prohibition) and the fixed, published fee schedule in Financial Independence. A confirmed case triggers the consequences set out in ASF-MON-STD-v1 Standard F2 for certified individuals, or the disciplinary process in HR, Recruitment and Role Conduct (ASF-POL-20) for Secretariat staff, and is reported under Feedback, Complaints and Incident Management (ASF-POL-21).
Red flags
| Area | Warning signs |
| Procurement | Same supplier always wins; quotes with identical formatting; splitting purchases; urgent single-source requests |
| Finance | Missing receipts; round-number invoices; payments to personal accounts; altered documents |
| Accreditation activity | Facility evidence files that are suspiciously complete at the last moment; Monitor findings that never vary; attendance at training that does not match certification records |
| People | Refusal to take leave or share duties; lifestyle beyond known income |
Prevention
- Segregation of duties and the approval matrix (ASF-POL-32)
- Competitive procurement and sanctions screening (ASF-POL-19, ASF-POL-25)
- Monthly bank reconciliation and an annual independent audit (ASF-POL-19)
- Fraud and ethics training on induction and annually thereafter
Recovery
ASF seeks to recover every lost amount from those responsible and reimburses donors for any ineligible cost, regardless of recovery outcome, with disclosure under Disclosure of Incidents to Donors (ASF-POL-35).