ASF Institutional Policy Manual · Aligned with PHIG, September 2026
Part of the ASF policy framework, aligned with the equivalent PHIG policy. To raise a concern: see the ASF Complaints and Reporting Channel.
ASF has zero tolerance for fraud, bribery and corruption by anyone acting for it, and every suspicion must be reported within 24 hours. Owner: Ethics Focal Point, as Financial Crimes Focal Point.
Definitions
- Fraud: knowingly making a false or misleading representation, or hiding information, to gain an advantage or cause a loss — for example false invoices, inflated timesheets, fake participants or duplicated claims.
- Bribery: offering, promising, giving, requesting or accepting anything of value to influence a decision.
- Facilitation payments: small unofficial payments to speed up a routine action. They are bribes and are prohibited.
- Corruption: abuse of entrusted power for private gain, including kickbacks, collusion in procurement, nepotism and embezzlement.
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 |
| Programmes | Participant lists with repeated names or signatures; attendance that does not match photos or venues |
| Research | Data that are “too clean”; missing source records; results changed after a funder’s comments |
| People | Refusal to take leave or share duties; lifestyle beyond known income |
Prevention
- Segregation of duties and the approval matrix (Policy 3).
- Competitive procurement (Policy 21) and sanctions screening (Policy 7).
- Monthly bank reconciliations and an annual independent audit (Policy 22).
- Fraud and ethics training on induction and every year.
- A fraud risk assessment for every project over 50,000 EUR.
Reporting and response
Report to the Ethics and Compliance Officer, the ASF Complaints and Reporting Channel or the Chair (Policy 13). The case is handled under Policy 14 and disclosed to donors under Policy 15. Where a crime may have occurred, ASF reports it to the relevant French authorities.
Recovery
ASF seeks to recover every lost amount from those responsible and reimburses donors for any ineligible cost, whatever the recovery outcome.