The Code of Conduct sets the mandatory standards for anyone who represents, works for, advises or contributes to the Sudan Policy Advisory Group. It exists to protect the integrity and independence of the Association, to govern the use of its authority and resources, to safeguard the people who engage with us, and to give a clear basis for preventing and addressing misconduct.
SPAG is an association governed by the French Law of 1 July 1901. The Code is an internal governance instrument adopted under the powers of the Association: it supplements the Statutes rather than amending them, and where it conflicts with the Statutes or with applicable law, the Statutes and the law prevail. Where a French-language legal text and an English-language policy text differ, the French text governs.
It applies wherever conduct is connected to a SPAG responsibility: on SPAG premises, during missions, meetings, events, consultations, research, training and travel, and through SPAG information systems and communication channels. Private conduct is not subject to institutional control merely because someone is associated with SPAG — it becomes relevant only where it creates a material conflict of interest, misuses SPAG authority or resources, or seriously compromises the ability to perform an entrusted role.
The Executive Bureau holds institutional oversight of the Code. Any disciplinary or administrative measure must be taken by the organ or person that actually holds that authority under the Statutes, a contract, employment law or another duly adopted policy — the Code confers no new power to sanction.
General standards
Act lawfully, in good faith and with loyalty to the statutory purposes of the Association, exercising responsibilities with competence, diligence, impartiality and respect for the dignity of others. No position, title, mandate, access or relationship may be used for improper personal, political, financial or organisational advantage.
Clause 4.1–4.2Independence and non-partisanship
Research, advice, appointments and partnerships are not directed by improper partisan, personal or financial influence. Individuals keep their private civic and political rights, but may not present personal views as SPAG positions, use SPAG resources for campaigning, or imply endorsement of a party, candidate or faction.
Clause 5.1–5.3Dignity and equality
Discrimination prohibited by French law has no place in SPAG decisions, recruitment, participation or working relations. Harassment, bullying, intimidation, threats and repeated hostile conduct are prohibited, and conduct that may constitute a criminal offence is not treated as an internal interpersonal dispute.
Clause 6.1–6.4Safeguarding and PSEAH
Zero tolerance for sexual exploitation, abuse and harassment connected to SPAG activities. Vulnerability, dependency, age, economic circumstance or control over access to assistance may never be exploited, and consent does not cure conduct obtained through coercion or abuse of authority.
Clause 7.1–7.3Conflicts, gifts and corruption
A conflict must be disclosed promptly and before the affected decision, with recusal where impartial participation cannot be maintained. Failure to disclose a material conflict is misconduct in itself, whatever the outcome of the decision. Bribery and corruption are prohibited in every direction.
Clause 8.1–8.5Research and intellectual integrity
Analysis is prepared in good faith with a clear line between evidence, judgement and advocacy, and material limitations are not concealed. Fabrication, falsification, plagiarism and manipulation of evidence are prohibited. Funding confers no right to predetermine findings.
Clause 9.1–9.4Financial integrity
Funds, assets, systems and intellectual property are used only for authorised institutional purposes under the applicable financial rules. Nobody may approve their own reimbursement, payment, contract or grant unless an approved control framework provides equivalent independent review.
Clause 10.1–10.3Confidentiality and personal data
Confidential, personal and security-sensitive information is accessed only on legitimate institutional need and handled in line with the GDPR and French data-protection law. The duty survives the end of the relationship — but may never be invoked to obstruct a protected report or a lawful investigation.
Clause 11.1–11.4Representation and external activity
Only authorised persons may issue official statements or bind SPAG, and a title may not imply authority beyond an actual mandate. Outside employment and academic work are permitted where they do not interfere with SPAG duties, misuse its resources or imply unauthorised institutional endorsement.
Clause 12.1–12.4Report
A concern goes to the channel that fits the subject matter — the whistleblowing mechanism, the safeguarding mechanism, a manager or focal point, the Director-General, the President or the Executive Bureau.
Clause 14.1–14.2Assessment
The receiving authority decides where the matter belongs: this Code, another policy, a contractual process, employment law, the Executive Bureau, or an external authority.
Clause 15.1Impartial review
Nobody with a conflict may investigate or decide; an independent reviewer may be designated. The person concerned is told the substance of the allegation and given a reasonable opportunity to respond before any adverse finding.
Clause 15.2–15.3Decision
Any measure is proportionate to the seriousness of the conduct and the responsibilities held, and may be taken only by the authority competent to impose it. Interim protective measures are precautionary, not findings.
Clause 15.4, 16.1–16.2Referral
Where the facts may amount to a criminal offence or create an immediate safeguarding risk, the matter may be referred to the competent authorities. An internal process never obstructs a lawful external investigation.
Clause 15.5Reasoned dissent is legitimate
Professional disagreement and critical analysis do not in themselves constitute misconduct. They are to be expressed with professional respect and within confidentiality obligations — but disagreeing is not a breach.
Abuse of authority is prohibited
Seniority, influence, decision-making power, control of resources or access to opportunities may not be used to intimidate, coerce, exploit or extract an improper advantage from another person.
No retaliation for a good-faith report
Retaliation for reporting, for taking part in an investigation, or for refusing to participate in misconduct is prohibited. Statutory whistleblower protections under French law apply where their conditions are met.
Good faith does not mean being proved right
A report is in good faith where there were reasonable grounds to believe it true at the time. Protection does not depend on the allegation ultimately being substantiated, and an unsubstantiated report is not itself misconduct.
A hearing before an adverse finding
The person concerned is informed of the substance of the allegation, so far as safeguarding and process integrity allow, and has a reasonable opportunity to respond. Findings rest on information fairly assessed.
Proportionality in any measure
The response weighs the nature, seriousness and frequency of the conduct, the responsibilities held, any abuse of authority, and mitigating and aggravating circumstances. Measures range from guidance to referral.
Membership is governed by the Statutes alone
Loss of membership follows Article 7 of the Statutes: the member must be invited by registered letter to give explanations before the Executive Bureau. This Code creates no automatic ground for expulsion.
Law prevails over policy
The Code cannot displace a mandatory rule of law, restrict a lawful report to a competent authority or regulator, or limit rights that cannot lawfully be waived. It is read consistently with the principle of proportionality.
Something to report?
Concerns about conduct, safeguarding, fraud or misuse of SPAG resources are handled through the Whistleblowing & Complaints mechanism, which sets out who receives a report, how confidentiality is protected and what happens next. Reports made in good faith are protected against retaliation.
