Foreword

Corruption kills. This is not a rhetorical claim. Corruption in healthcare procurement inflates the price of medicines and medical equipment. Corruption in accreditation — where an organisation purchases a quality credential rather than earning it — exposes patients to facilities that have not met the safety standards the certificate claims. Corruption in international development transfers resources intended for vulnerable populations to those with power. ASF operates at the intersection of all three.

An accreditation body’s most valuable asset is the trust that the credential it issues accurately represents the quality of the facility that holds it. That trust is destroyed the moment an accreditation decision is influenced by anything other than the evidence from a competent, independent survey. This policy exists to make explicit what is already implicit in ASF’s founding purpose: that integrity is not negotiable, and that the prohibition on corruption and bribery is absolute — no exception for jurisdiction, no exception for commercial pressure, no exception for scale.

As a French-registered international body, ASF’s obligations derive from the UN Convention Against Corruption (UNCAC), the OECD Anti-Bribery Convention, French loi Sapin II, and ISO 37001. This policy does not merely note those obligations — it implements them through specific, auditable commitments: a gifts and hospitality register, a three-level due diligence framework for partners, a political contributions prohibition, and a protected reporting channel. Each commitment is documented in a named procedure or record that can be produced on request by any external auditor or ISQua EEA reviewer.

1. Commitment Statement

Accréditation Sans Frontières will not engage in corruption or bribery in any form, in any jurisdiction, at any level. This is an absolute prohibition. No exception exists for facilitation payments, for jurisdictions where corruption is widespread, for commercially advantageous situations, or for any other reason.

ASF’s value is its integrity. An accreditation body that pays a bribe to obtain a contract, a surveyor appointment, or a government endorsement has destroyed the credential it issues. This policy is not primarily a legal compliance document — though it addresses legal obligations — it is an organisational statement that ASF’s credibility depends on absolute integrity, and that no short-term commercial advantage justifies compromising it.

2. Legal Framework

As a French-registered organisation operating internationally, ASF is subject to:

• UN Convention Against Corruption (UNCAC, 2003) — ratified by France in 2005; ratified by Georgia in 2008; establishes binding international obligations on corruption prevention, criminalisation, international cooperation, and asset recovery [1]
• OECD Convention on Combating Bribery of Foreign Public Officials (1997) — ratified by France; criminalises bribery of foreign public officials by French legal persons and natural persons [2]
• French loi Sapin II (2016) — requires French organisations of sufficient size to establish an anti-corruption compliance programme. While ASF’s current size falls below the employee threshold for mandatory programme requirements, the standard the law establishes governs ASF’s approach [3]
• ISO 37001:2016 (Anti-Bribery Management Systems) — the international management system standard for anti-bribery; this policy aligns with its principles without committing to certification [4]

3. Prohibited Conduct

The following are absolutely prohibited for all persons acting on ASF’s behalf:

4. Gifts and Hospitality

Not all gifts and hospitality are corruption. The distinction is whether the gift or hospitality is of a kind, value, or timing that could improperly influence — or be perceived to improperly influence — a decision. The following limits apply:

All items requiring approval must be declared to the Council Chair (for Council members and surveyors) or to the ASF Director (for staff and contractors) before the gift or hospitality is accepted or provided. Declared items are logged in the Gifts and Hospitality Register maintained by the Council secretariat. Unexpected gifts (items received without prior solicitation or opportunity for advance declaration — for example, a gift delivered by post) must be declared to the Council Chair or ASF Director within five working days of receipt. Items over €150 received unexpectedly must be returned or, where return is not possible or would cause offence, donated to a charity nominated by the Council Chair and recorded in the Register.

4b. Political Contributions and Trading in Influence

UNCAC Article 18 specifically addresses trading in influence — the solicitation or receipt of an undue advantage in exchange for using real or supposed influence to obtain improper benefits from a public authority. This form of corruption is particularly relevant for an accreditation body that seeks government recognition or regulatory endorsement in multiple jurisdictions.

ASF does not make, and will not make, political contributions to any political party, candidate for political office, or political campaign in any jurisdiction. This prohibition is absolute and applies to direct contributions, in-kind contributions, and contributions made through third parties. It does not apply to legitimate engagement with public health policy processes — responding to government consultations, participating in regulatory working groups, or submitting evidence to parliamentary or legislative inquiries — which are distinct from political contributions and are part of ASF’s legitimate advocacy function.

The Gifts and Hospitality Register maintained under Section 4 is reviewed by the Council Chair annually. A summary of declarations made and any items requiring approval during the year is included in the Annual Activity Report.

5. Due Diligence on Partners and Suppliers

ASF applies proportionate due diligence to third parties acting on its behalf — local delivery partners, training providers, and significant suppliers — before engagement. Due diligence is proportionate to the risk: a local partner in a jurisdiction scoring below 40 on the Transparency International Corruption Perceptions Index (CPI) — the threshold broadly associated with systemic corruption risk — requires more thorough due diligence than a supplier in a jurisdiction scoring above 60. The CPI is updated annually and ASF reviews partner risk classifications accordingly.

Due diligence is applied at three levels:

The Outsourcing Policy (ASF-OUTSOURCE-001-v2) requires all significant third-party agreements to include an anti-corruption clause requiring the third party to comply with this policy and to notify ASF if they become aware of any corruption risk in the engagement.

6. Reporting and Investigation

Any person who suspects or becomes aware of a violation of this policy must report it under the ASF Internal Whistleblower Protection Policy (ASF-WHISTLE-001-v2). Reports may be made anonymously. Retaliation against a person who makes a good-faith report is a separate violation of the Code of Conduct and this policy.

Reported violations are investigated independently. Where a violation is confirmed, the individual concerned is subject to immediate suspension and, following investigation, removal from their ASF role. Where a violation involves a criminal offence under applicable law, ASF cooperates fully with law enforcement.

References

1. United Nations. United Nations Convention Against Corruption. New York: UNODC; 2003.
2. OECD. Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. Paris: OECD; 1997.
3. France. Loi n° 2016-1691 du 9 décembre 2016 relative à la transparence, à la lutte contre la corruption et à la modernisation de la vie économique (loi Sapin II). Paris: Légifrance; 2016.
4. ISO. ISO 37001:2016 — Anti-Bribery Management Systems. Geneva: ISO; 2016.