This Policy sets out how SPAG receives, protects, assesses, investigates, answers and closes whistleblowing reports and complaints. It exists to provide channels that can be trusted, to protect people who report in good faith, to preserve the rights of anyone accused, and to let the Association find and fix misconduct, governance failures and risks to its integrity.
Anyone may use it. Members, office-holders, staff, consultants, advisers, volunteers and interns are covered, and so are participants, community members, partners, suppliers, applicants, former personnel and website users affected by SPAG's conduct. Reports are accepted in English, French or Arabic.
You do not have to come to SPAG first. French law lets an eligible person report directly to a competent external authority, the Défenseur des droits, the judicial authority or a competent body of the European Union, and SPAG may not require internal reporting as a precondition, obstruct a lawful external report or penalise anyone for making one.
Nor does this Policy replace the emergency services, the police, child-protection authorities or a regulator. Where there is immediate danger, suspected serious criminal conduct or a mandatory reporting duty, use the competent external mechanism without waiting for SPAG to act.
The designated channel
SPAG maintains a designated Whistleblowing and Complaints channel and publishes the information needed to reach it. The Executive Bureau may appoint a Focal Point, a case-management function or an independent external recipient. Where an oral option is available, you may ask for a confidential discussion or meeting instead of writing.
Clause 8.1–8.2A non-conflicted office-holder
A concern may go to the Focal Point, the Director-General, the President or any non-conflicted member of the Executive Bureau. Where the normal recipient is the subject of the allegation, it must be transferred elsewhere: a report about the President, Director-General, Secretary-General or Treasurer is never handled by that person alone, and one about the Bureau collectively goes to an independent external reviewer.
Clause 8.2–8.3Anonymously
Anonymous reports are accepted where the channel permits anonymity, and a matter is not rejected solely because the reporting person is anonymous. Anonymity may limit SPAG's ability to seek clarification or give you feedback. No attempt is made to identify an anonymous reporter unless that is necessary and lawful for a compelling reason.
Clause 8.5, 13.5Directly to an external authority
An eligible person may report externally without telling SPAG first — to a competent authority, the Défenseur des droits, the judicial authority or a competent EU institution. The Défenseur des droits can also inform, orient and protect whistleblowers, and direct you to the body best placed to handle the matter.
Clause 2.3, 2.7, 8.6Where to send it
The designated channel is integrity@sudanadvisory.org. A report may also be given directly to the Whistleblowing and Complaints Focal Point, the Director-General, the President, or any non-conflicted member of the Executive Bureau — and where the concern involves one of them, to another of them. It may be made in English, French or Arabic, and anonymously. A concern is never refused because it reached the wrong SPAG office: passing it onward changes neither its original receipt date nor the protection attached to it.
The general enquiry form is not a reporting channel. Safeguarding concerns, complaints and protected disclosures are handled under this separate confidential procedure, and an eligible person may in any case report directly to an external authority without approaching SPAG at all.
Receipt
Whoever receives it preserves the information, avoids circulating it and passes it promptly to the case-management function. No recipient may open an informal investigation of their own.
Clause 9.1Acknowledgement
Where contact details exist, SPAG acknowledges in writing within seven working days, identifies the channel handling the matter, explains the next step and states any limits on confidentiality.
Clause 9.2Triage
Every matter is classified and checked for immediate safety or retaliation risk, urgency, credibility, legal reporting duties, conflicts of interest, preservation of evidence and whether a referral is needed.
Clause 10.1–10.2Assessment
A preliminary assessment decides between no further action, clarification, informal resolution, corrective action, specialist referral, formal investigation or external referral. It makes no premature finding.
Clause 14.1Investigation
Commissioned only where necessary, under a written mandate, by someone competent, impartial and free of conflict. The report must separate established facts, contested facts, evidentiary limits, analysis and recommendations.
Clause 14.2–14.5Outcome
The competent authority determines the result and any proportionate action, from correcting a process to referral to an external authority. You are told of closure and, so far as appropriate, the reasons.
Clause 16.1–16.2, 17.4Written acknowledgement of a report or complaint, where contact details are available.
Clause 9.2, 17.1Target for a substantive response or status update on a general complaint. Where a matter is too complex to conclude in that time, you are told of the delay and given an indicative revised timeframe.
Clause 17.2For a matter handled as a potential statutory alert: written information on the measures envisaged or taken to assess and, where appropriate, remedy what was reported.
Clause 17.1To ask for a review of how your case was handled. One review may be requested on grounds of a material procedural defect, a material conflict of interest, significant new evidence or a manifestly unreasonable conclusion. It is conducted by someone who did not make the original decision.
Clause 17.5Whistleblowing report
A report that may fall within the statutory regime, or that SPAG treats as concerning serious wrongdoing, illegality, a threat or harm to the public interest, or concealment of such conduct. Whether you qualify for statutory protection is decided by law, not by the label SPAG puts on the report.
Complaint
Dissatisfaction or an allegation about SPAG conduct, a service, process, decision, relationship or omission affecting you or someone you represent. A complaint may involve misconduct without meeting the legal definition of whistleblowing.
Safeguarding concern
Sexual exploitation, sexual abuse, sexual harassment, harm to a child or another safeguarding risk. It is governed by the Safeguarding and PSEAH Policy, and a concern raised here is routed there without asking you to submit it a second time.
Grievance
A concern arising mainly from an employment or engagement relationship — working conditions, management decisions, interpersonal treatment. It may be routed to an HR process, but allegations of retaliation, discrimination, corruption, harassment or serious misconduct are not excluded just because they arose at work.
You do not have to prove it
A reporting person is not required to prove an allegation before making a report, or to gather evidence — still less to obtain it unlawfully. A report is not rejected merely because the supporting evidence is incomplete, where the allegation is credible enough to warrant assessment.
Retaliation is prohibited
Dismissal, demotion, refusal of promotion, disadvantageous reassignment, reduced pay or hours, denial of training, intimidation, ostracism, blacklisting, unjustified adverse references, non-renewal of a contract or exclusion from SPAG activities, where linked to a report, are all prohibited — as are threats and attempts.
Retaliation is assessed on its own
If you believe you have been retaliated against, report it immediately. That allegation is assessed separately from the underlying report and may justify interim protective measures in its own right.
Confidentiality, honestly described
Identities are disclosed only to those who need them for a legitimate, lawful purpose, and statutory confidentiality is strictly observed. Nobody handling a case will promise absolute confidentiality: disclosure can be required for safety, due process, legal reporting or judicial proceedings.
The person accused has rights too
They are presumed not to have committed misconduct until the matter is substantiated, are told the substance of the allegation at an appropriate stage, and get a reasonable opportunity to respond before any adverse internal finding. Nobody is publicly identified merely because an allegation exists.
An unsubstantiated report is not a false one
Knowingly fabricating an allegation to harm someone may be misconduct. But a report is not treated as malicious merely because it turned out to be unsubstantiated, mistaken, incomplete or withdrawn.
Impartial handling
Nobody may receive, investigate, decide or review a matter where they hold an actual conflict of interest or a relationship that would reasonably call their impartiality into question. The matter is reassigned, or an independent external person is appointed.
Data handled under the GDPR
Case data is processed only for specified legitimate purposes, limited to what is necessary, kept secure, and retained only as long as is proportionate to handling the case, protecting those concerned and any applicable limitation period.
