Global Fund Requirements for Risk Management at Implementer Level

The Global Fund considers that the implementers have the primary responsibility of managing risks in the grants they implement. This means that risk management at the Principal Recipient (PR) level is supported by the PR’s internal controls systems. The Global Fund Risk Management Policy stipulates that implementers have an obligation to operate internal control systems to ensure that:

  • Funds are efficiently and effectively directed to achieving programmatic results and reaching people in need; and
  • Programmatic and financial data are accurate, timely and complete.

Where Sub-recipients (SRs) are engaged,  the PR has the overall responsibility to manage the SRs and how the SRs manage Sub-sub-recipients (SSRs), if any are engaged. For more information on management of SR-related risks by PRs, please refer to the SR management section of the Manual. In addition, as part of their oversight of grant implementation, Country Coordinating Mechanisms (CCMs) play a role in managing risk by detecting weaknesses in performance or control systems, and promoting remedial action.

While the Global Fund does not mandate any tool or practice for risk management at the PR level, there are some requirements related to risk management during the grant life cycle.

By signing the Grant Agreement, the PR accepts the responsibility of managing the grant(s), which includes any and all risks related to them. It is common practice for PRs to engage other entities (SRs) to implement some grant activities. It is important to keep in mind that while the PR may delegate some specific work or activities to SRs, it cannot delegate the risk of said activities. The PR is always accountable. Therefore, the PR should undertake a robust assessment of SR capacity and any risks related to their activities and their internal control and systems, and plan accordingly. This plan should be regularly monitored and updated during grant implementation.