This Policy sets out how SPAG prevents, detects, reports and responds to fraud, bribery, corruption, influence peddling and related financial misconduct. It protects the Association's resources and independence, and the people and institutions it works with.
The prohibition is unconditional. No approval, instruction, custom, emergency, seniority or institutional interest can authorise conduct that is unlawful or prohibited here — and performance targets, funding pressure, humanitarian urgency, political sensitivity, relationship management and local practice are all expressly ruled out as justifications.
It reaches beyond SPAG's own people. Contractors, service providers, implementing partners, sub-grantees, agents and intermediaries who receive SPAG funds, spend on its behalf or represent its interests are brought within it by agreement, and nobody may sidestep the Policy by acting through a relative, intermediary, supplier or affiliated organisation.
SPAG adopts the preventive logic of the French Sapin II framework voluntarily and proportionately. It does not claim that Article 17 of that law applies to the Association unless a legal assessment establishes that it does.
Fraud and false representations
False invoices, fictitious suppliers or beneficiaries, fabricated receipts, altered supporting documents, false expense claims and timesheets, duplicate claims, inflated prices, unauthorised personal expenditure, diversion of grant funds, manipulated procurement records and concealment of losses. Certifying delivery, attendance or eligibility you have not reasonably verified counts too.
Clause 6.1–6.4Bribery in either direction
No advantage may be offered, promised, authorised, given, solicited, requested or accepted to influence or reward an improper act, decision, recommendation, procurement, appointment, payment, permit, partnership or funding outcome. The prohibition covers commercial, civil-society, academic, grant-making and public-sector relationships alike.
Clause 5.2, 7.1–7.2Advantages need not be money
Employment and internships, favourable research treatment, speaking opportunities, sponsorship, travel, charitable support, confidential information and preferential access can all be improper advantages depending on purpose and context. So can political, family, tribal, sectarian, professional or personal connections used to circumvent a lawful process.
Clause 4.5, 7.3, 8.5Public officials and influence peddling
Nothing of value may go to a public official, or to someone connected with one, to obtain or retain an improper decision, access, contract, grant, authorisation or endorsement. No intermediary may be paid to exercise real or supposed influence over a public authority; public-sector advisory work needs a documented legitimate scope and reasonable remuneration.
Clause 8.2–8.3Facilitation payments
No payment outside an official fee schedule or lawful receipted process may be made merely to accelerate a routine governmental or administrative action — regardless of how small, how customary, or how entitled SPAG is to the outcome. The single exception is an immediate threat to safety, addressed below.
Clause 4.7, 9.1Gifts, hospitality and travel
Benefits may be offered or accepted only where lawful, reasonable, proportionate, transparent, infrequent and tied to a legitimate professional purpose. Cash equivalents, gift cards and private loans are excluded outright. Anything involving a public official, high-value hospitality or externally funded travel needs prior written review.
Clause 10.1–10.4Donations and political contributions
Donations, sponsorships and grants may not be used to disguise bribery, private benefit, political financing or diversion of funds, and no contribution goes to an entity chosen by an official, donor or supplier in order to influence them. SPAG makes no political contributions to parties, candidates or campaigns — which does not restrict lawful non-partisan policy work.
Clause 11.1–11.4Books, records and controls
Transactions are recorded accurately and in enough detail to show their true purpose and economic substance. Off-book accounts, undisclosed funds, false descriptions and fictitious entries are prohibited, as is splitting, backdating, reclassifying or restructuring a transaction to duck an approval threshold, procurement requirement, due-diligence review or donor condition.
Clause 14.1–14.2, 14.5If your safety is threatened, your safety comes first
Where someone reasonably believes a payment or transfer is necessary to prevent an immediate and credible threat to life, physical safety or liberty, personal safety takes priority. The Policy does not treat such a payment as an authorised facilitation payment, and nobody is expected to refuse one under duress. Report it as soon as it is safe to do so, and record it accurately — the circumstances, the amount, the recipient if known, and why the threat was believed to be immediate. A false description must never be used to conceal it. The Executive Bureau reviews such incidents to decide whether additional security measures, legal advice or operational restrictions are needed.
Report
Through the Whistleblowing & Complaints channels. You need not hold complete evidence — but separate, so far as you can, what you know personally, what you were told, and what you suspect.
Clause 17.1–17.2Triage
Weighing urgency, conflicts of interest, the risk of continuing loss, evidence preservation, safeguarding or security implications, and any legal or donor notification requirement.
Clause 18.1Protect
Proportionate interim measures may follow: suspended payments, restricted access, preserved accounts or devices, a suspended engagement, enhanced approvals. Precautionary, not findings.
Clause 18.3Investigate
By people independent of the matter so far as practicable. Records and digital evidence are preserved lawfully, with access to personal data limited to what is necessary. External auditors, lawyers or forensic specialists may be engaged.
Clause 18.2, 18.4, 18.6Act
Proportionate to seriousness, role, loss, intent and cooperation: withdrawn authority, disciplinary action, terminated contracts, exclusion from procurement, corrected records, strengthened controls, notification to a funder.
Clause 19.1–19.2Recover and refer
Losses, overpayments and misappropriated property are pursued where lawful and proportionate, and matters are referred to competent authorities where required. Legal advice precedes any voluntary disclosure, complaint or settlement of significance.
Clause 19.4–19.5Nobody can authorise it
No approval, instruction, custom, emergency, seniority or institutional interest authorises conduct that is unlawful or prohibited here. An exception may never be granted to a prohibition imposed by law.
The attempt is the offence
Conduct stays prohibited whether or not the intended outcome is achieved, whether or not the advantage actually changes hands, and whether it is done directly or through someone else.
Not knowing on purpose is no defence
No payment or arrangement may be authorised while deliberately avoiding knowledge of facts indicating it is likely to be used for bribery or corruption. Uncertainty about legality is a reason to refer the question, not to proceed.
Refuse, then report
Anyone asked for an improper payment refuses where it is safe and practicable to do so, and reports the request promptly. Nobody investigates a suspected fraud on their own initiative — uncoordinated inquiries compromise evidence, confidentiality, safety and due process.
No retaliation
Nobody may be penalised for raising a concern in good faith, refusing to take part in prohibited conduct, or cooperating with an authorised investigation.
Unsubstantiated is not bad faith
Knowingly false or malicious allegations may be misconduct. But a report that is not substantiated does not, by itself, establish that it was made in bad faith. Nothing here restricts a report to a competent external authority where the law permits or protects it.
Recovery is never bought with silence
SPAG pursues recovery of losses where lawful and proportionate — but recovery is never conditioned on silence or on not reporting conduct that must lawfully be disclosed.
Closed is not necessarily final
Closing an internal matter does not prevent later action if new evidence emerges or a competent authority requires it. SPAG also does not knowingly retain a benefit obtained through fraud, bribery or corruption.
Seen something that does not add up?
Suspected fraud, bribery, corruption, influence peddling, misappropriation or deliberate circumvention of controls is reported through the Whistleblowing & Complaints mechanism, which sets out who receives it, how confidentiality is protected and what happens next. You do not need proof to raise it.
