Global Fund Additional Safeguards Policy

Additional Safeguards Policy (ASP) is a set of measures that the Global Fund introduces whenever “the existing systems to ensure accountable use of Global Fund financing suggest that Global Fund monies could be placed in jeopardy without the use of additional measures”. Examples of criteria for invoking ASP include significant concerns about governance; the lack of a transparent process for identifying a broad range of implementing partners; major concerns about corruption; a widespread lack of public accountability; recent or ongoing conflict in the country or region of operation; political instability or lack of a functioning government; poorly developed or lack of  civil society participation; financial risks such as hyperinflation or devaluation; or lack of a proven track record in managing donor funds.

The ASP can be found in the Global Fund Operations Policy Manual. The ASP is usually invoked for the entire portfolio of Global Fund grants, on a countrywide basis.

The specific additional safeguard measures put in place are adapted to the risks and circumstances of each concerned grant. They may include:

  • The Global Fund itself selecting the Principal Recipient (PR), in consultation with the Country Coordinating Mechanism (CCM);
  • The Global Fund approving Sub-recipients (SRs);
  • Additional reporting requirements;
  • Tailored procurement arrangements; and
  • In some cases, a no-cash policy (also referred to by the Global Fund as ‘Zero Cash Policy’), which prohibits advance cash transfers to SRs that pose a particular risk.

UNDP is often nominated as PR in ASP countries.  As UNDP-implemented Global Fund projects adhere to UNDP’s regulations, rules, policies and procedures, not all Global Fund measures apply. Most flexibilities would be negotiated during grant-making and the Country Office (CO) is advised to request support of the UNDP Global Fund/Health Implementation Support Team.