SUBGRANTING POLICY of the PF “NASH VEK”

PUBLIC FOUNDATION “NASH VEK”

SUBGRANTING POLICY

For Public Monitoring and Promoting Civil Society Participation in Sustainable Development Processes

Policy period: 2026–2030

1. General Provisions

1.1. This Subgranting Policy (hereinafter referred to as the “Policy”) establishes the objectives, principles, procedures and requirements governing the provision of subgrants by the Public Foundation “Nash Vek” (hereinafter referred to as the “Foundation” or “PF Nash Vek”) to civil society organisations, initiative groups and other eligible categories of recipients for the purposes of conducting public monitoring, independent analysis and promoting accountability in development processes.

1.2. The Policy has been developed to ensure the transparent, fair, efficient and accountable use of funds received by the Foundation from international and national donors, charitable organisations and other lawful sources of funding.

1.3. The Policy applies where the Foundation receives funding that provides for the possibility of subsequently allocating a portion of the funds to other organisations or groups to implement independent initiatives consistent with the objectives of the funded programme.

1.4. Subgrants shall be provided in accordance with the legislation of the Kyrgyz Republic, the Foundation’s Charter, the terms of donor agreements and this Policy.

Where a donor agreement establishes additional or more stringent requirements for subgranting, the Foundation shall apply those requirements to the relevant programme, provided that they are compatible with the legislation of the Kyrgyz Republic.

1.5. This Policy shall be applied together with the Foundation’s internal documents governing financial management, prevention of conflicts of interest, procurement, prevention of fraud and corruption, personal data protection and complaint handling.

2. Objectives and Tasks of the Subgranting Programme

2.1. The primary objective of subgranting is to strengthen the capacity of civil society to conduct independent public monitoring and enhance the transparency and accountability of public authorities, international financial institutions and other actors involved in development processes.

2.2. The tasks of subgranting programmes are to:

  1. Support public monitoring of projects implemented by international financial institutions, projects funded through international technical and financial assistance, infrastructure projects and other development initiatives.
  2. Identify and document the social, economic, environmental and other impacts of projects on local communities.
  3. Expand the participation of citizens affected by projects in decision-making processes and complaint-handling mechanisms.
  4. Build the capacity of local organisations, initiative groups, independent researchers and public monitoring teams.
  5. Promote access to information, public consultations and respect for the rights of affected populations.
  6. Prepare independent analytical materials, monitoring reports, recommendations and proposals for addressing identified problems.
  7. Strengthen regional civil society networks and cooperation among civil society organisations.
  8. Support the implementation of the Sustainable Development Goals and improve the effectiveness, transparency and accountability of development processes.

2.3. The specific priorities, geographical coverage, duration, funding allocation and expected results shall be determined separately for each subgranting programme, taking into account the donor’s objectives and the Foundation’s strategic priorities.

3. Core Principles

The Foundation shall be guided by the following principles.

Transparency. Information about calls for proposals, selection criteria, application deadlines and decision-making procedures shall be communicated to potential applicants in an accessible manner.

Fairness and Equal Opportunities. All applicants who meet the established requirements shall have equal opportunities to participate in the competition.

Independence. Receiving a subgrant shall not deprive the recipient of the right to draw independent conclusions, critically assess projects and publish monitoring results in accordance with the agreement, safety requirements and applicable legislation.

Objectivity. Decisions on the award of subgrants shall be based on pre-established criteria and documented assessment results.

Accountability. Recipients shall use funds for their approved purposes and submit substantive and financial reports.

Proportionality of Requirements. Administrative and reporting requirements shall be proportionate to the amount of the subgrant, the level of risk and the donor’s conditions. The Foundation shall seek to avoid creating excessive barriers for small regional organisations and initiative groups.

Participation of Affected Communities. Priority shall be given to initiatives that provide for meaningful participation by local residents and take their experiences and views into account.

Prevention of Harm. Risks to participants, applicants, information sources and affected communities shall be considered when planning and implementing monitoring activities.

Integrity. The Foundation shall not tolerate fraud, corruption, bribery, misuse of funds or manipulation of competitive procedures.

4. Terms and Definitions

For the purposes of this Policy, the following terms shall apply:

Subgrant — targeted funding provided by the Foundation to another eligible recipient to independently implement an initiative or part of a programme in accordance with approved objectives, activities, budget and contractual terms.

Subgranting Programme — a set of activities undertaken by the Foundation to announce calls for proposals, select recipients, award subgrants, provide implementation support and monitor implementation.

Subgrant Recipient — a legal entity, initiative group or other person eligible to receive funding under the conditions of a specific programme and applicable legislation.

Public Monitoring — the systematic collection, analysis and verification of information concerning project implementation, the use of funds, compliance with obligations and impacts on the population and the environment.

Selection Committee — a collegial body established by the Foundation to review and evaluate applications and make recommendations on the selection of recipients.

Conflict of Interest — a situation in which a person’s personal, family, financial, professional or other interests may influence, or reasonably appear to influence, the objectivity of their decisions.

Donor — an organisation or individual providing funding to the Foundation for programme implementation, including programmes that include a subgranting component.

5. Priority Areas for Subgranting

Depending on the objectives of a specific programme, subgrants may be awarded for the following activities:

  1. Monitoring projects implemented by international financial institutions and other development-financing organisations.
  2. Monitoring projects financed through external assistance, international loans, grants and public funds.
  3. Researching the impacts of infrastructure, energy, transport, water management and other projects on local communities.
  4. Documenting violations of procedures concerning public consultations, access to information, resettlement, compensation and other social and environmental obligations.
  5. Organising meetings with affected populations, public discussions and consultations.
  6. Preparing independent monitoring reports, case studies, analytical briefs and recommendations.
  7. Engaging with accountability mechanisms of international financial institutions and other established complaint-handling mechanisms.
  8. Developing regional monitoring groups, training local activists and strengthening their competencies.
  9. Monitoring the implementation of recommendations aimed at addressing identified problems.
  10. Disseminating monitoring results, conducting information activities and organising public campaigns.
  11. Other activities consistent with the Foundation’s mission and the terms of the funding.

The list of priorities may be further specified in each call for proposals.

6. Subgrant Recipients and Applicant Requirements

6.1. Depending on the conditions of a specific programme, subgrant recipients may include:

  • Non-profit organisations registered in the Kyrgyz Republic;
  • Regional and local civil society organisations;
  • Public associations and initiative groups working with local communities;
  • Independent monitoring teams;
  • Research and expert groups;
  • Other organisations and individuals, provided that their participation is permitted by applicable legislation and donor requirements.

6.2. The Foundation may establish different categories of recipients and separate competition requirements for registered organisations and informal initiative groups.

6.3. The main requirements for applicants are:

  1. The proposed initiative must be consistent with the objectives and priorities of the call for proposals.
  2. The application must identify a clearly substantiated problem, objectives, an activity plan and expected results.
  3. The proposed budget must be realistic.
  4. The applicant must have sufficient experience or demonstrate a reasonable capacity to implement the initiative.
  5. The applicant must be willing to comply with contractual terms, financial reporting requirements and safety rules.
  6. There must be no unresolved circumstances that prevent the responsible use of funds.

For small initiatives, an applicant’s capacity may be demonstrated through the experience of key team members, participation in monitoring activities, cooperation with local communities and other proportionate evidence.

6.4. The Foundation shall not require applicants to demonstrate a large financial turnover, a substantial administrative structure or experience in managing large grants unless such requirements are justified by the nature of the initiative, the level of risk or donor conditions.

6.5. An applicant’s critical position regarding the activities of public authorities, international financial institutions, contractors or other project stakeholders shall not, in itself, constitute grounds for refusing a subgrant.

6.6. Applicants shall disclose information about potential conflicts of interest and other circumstances that could materially affect the independence of monitoring.

7. Activities Ineligible for Funding

Subgrant funding shall not be used for:

  1. Activities prohibited by the legislation of the Kyrgyz Republic.
  2. The use of funds for personal purposes unrelated to the implementation of the initiative.
  3. Fraud, corruption, bribery, unlawful remuneration and other improper conduct.
  4. Activities intended to promote discrimination, violence or persecution on grounds protected by law.
  5. Political activities where such activities are excluded by the donor’s conditions or by the legislation applicable to the specific recipient.
  6. Double funding of the same expenses from multiple sources without disclosure and approval in accordance with the established procedure.
  7. Expenses not included in the approved budget and not authorised where such authorisation is required.
  8. Activities that create unacceptable risks for monitoring participants where those risks cannot reasonably be mitigated.
  9. Other expenses and activities prohibited by the terms of the relevant donor funding.

Payment for goods, services and work directly necessary to achieve the objectives of a subgrant shall be permitted, provided that such costs are justified, consistent with the approved budget and compliant with applicable rules.

8. Planning a Subgranting Programme

8.1. Before announcing a call for proposals, the Foundation shall determine:

  • The programme’s objectives and tasks;
  • Thematic and geographical priorities;
  • Categories of eligible applicants;
  • The total amount of funding allocated to subgrants;
  • The indicative amount of an individual subgrant;
  • The implementation period;
  • Eligible expenses;
  • Co-financing requirements, if stipulated by the donor;
  • Application, reporting and monitoring requirements;
  • Assessment criteria and decision-making procedures;
  • Complaint-handling procedures.

8.2. The Foundation may establish different subgrant amounts, such as small, standard and larger grants, where this is consistent with the programme’s objectives and available funding.

8.3. The terms of the call shall be approved by the Director of the Foundation or another authorised body in accordance with the Charter, the internal allocation of responsibilities and the requirements of the donor agreement.

8.4. A call for proposals shall be announced only after funding has been confirmed and the necessary preliminary conditions established by the donor have been met.

8.5. The Foundation shall not undertake obligations to award subgrants beyond its available and confirmed financial resources.

9. Announcement of Calls and Submission of Applications

9.1. Information about calls for proposals shall be published on the Foundation’s official website, social media, professional civil society networks, regional information channels and through other accessible means.

9.2. At a minimum, each announcement shall specify:

  • The objectives and priorities of the call;
  • Who is eligible to apply;
  • The available funding or subgrant amount range;
  • The implementation period for initiatives;
  • The list of required documents;
  • The assessment criteria;
  • The application deadline and submission method;
  • A contact person for enquiries;
  • The procedure for notifying applicants of the results;
  • The procedure for submitting a complaint regarding the competition process.

9.3. Applications may be submitted in Russian and Kyrgyz and, where necessary, in other languages specified in the call conditions.

9.4. The Foundation may use simplified application forms for small subgrants to ensure access for regional initiatives and groups with limited organisational resources.

9.5. An application shall include a description of the problem, objectives, activity plan, expected results, budget, applicant information and details of any potential conflict of interest.

9.6. The Foundation shall ensure the confidentiality of applications and use the information they contain only for selection, programme management, fulfilment of legal obligations and compliance with donor requirements.

10. Application Review and Selection

10.1. Selection shall be conducted in accordance with criteria published in advance. The Foundation shall not arbitrarily change the criteria after applications have been received.

10.2. The initial screening shall verify compliance with formal requirements, the applicant’s eligibility and the initiative’s relevance to the subject of the call.

10.3. Applications that pass the initial screening shall be assessed on their merits.

The following indicative scoring system may be used:

Criterion Maximum score
Alignment with the objectives and priorities of the call 20
Significance of the problem and potential public impact 20
Quality of the methodology and monitoring plan 20
Participation of local communities and affected populations 15
Budget realism and value for money 15
Applicant capacity, safety and sustainability of results 10
Total 100

The Foundation may adapt the criteria and their weighting for each call to reflect the specific characteristics of the programme. The final criteria shall be approved and published before the assessment begins.

10.4. The Director of the Foundation shall establish a Selection Committee to evaluate applications. The Committee may include Foundation staff, independent experts and civil society representatives.

10.5. Committee members shall disclose any potential conflicts of interest before the assessment begins. A person with a conflict of interest concerning a particular applicant shall not participate in the discussion or evaluation of that application. Disclosures and measures taken to address conflicts shall be documented.

10.6. Following the assessment, minutes shall be prepared, listing the applications reviewed, scores awarded, the Committee’s recommendations and the rationale for the proposed decision.

10.7. The final decision shall be made by the authorised person or body of the Foundation in accordance with the Charter, approved procedures and donor requirements.

10.8. The Foundation shall notify applicants of the competition results. Where possible, applicants shall receive brief feedback.

10.9. If a material error in the selection procedure is identified, the Foundation may conduct a reassessment, reconsider the decision or cancel the competition in accordance with the established procedure, documenting the reasons.

11. Prevention of Conflicts of Interest

11.1. Foundation employees, Selection Committee members, external experts and other persons involved in the selection and monitoring of subgrants shall act with integrity and objectivity.

11.2. Persons involved in decision-making shall not use their official position to grant unjustified advantages to relatives, affiliated organisations, business partners or other related persons.

11.3. If a prospective recipient is connected to a Foundation employee or Committee member, that relationship shall be disclosed before a decision is made. The application may be considered only where permitted by the applicable rules and donor conditions, and the interested person shall be excluded from the relevant procedures.

11.4. The Foundation shall maintain documented records of disclosed conflicts of interest and the measures taken to resolve them.

11.5. The solicitation or acceptance of improper payments, gifts or other benefits in exchange for a favourable subgrant decision is prohibited.

12. Subgrant Agreement

12.1. Before funding begins, the Foundation shall enter into a written subgrant agreement with the recipient.

12.2. The agreement shall specify:

  1. The parties and subject matter of the agreement.
  2. The objectives and expected results of the initiative.
  3. The implementation period.
  4. The funding amount and disbursement schedule.
  5. The approved budget and eligible expenses.
  6. The procedure for amending the activity plan and budget.
  7. Substantive and financial reporting requirements.
  8. Monitoring and verification procedures for the use of funds.
  9. Requirements for retaining supporting documents.
  10. The parties’ obligations to prevent fraud and conflicts of interest.
  11. Requirements for personal data protection, participant safety and confidentiality.
  12. Procedures for using and publishing monitoring results.
  13. Grounds for suspending payments, terminating the agreement and recovering funds.
  14. Procedures for resolving disputes and the applicable law.

12.3. The agreement shall not contain requirements obliging the recipient to distort monitoring results, conceal substantiated findings or abandon an independent assessment of a project.

12.4. Rights to the results, publication procedures and rules for using materials shall be determined by the agreement, taking into account applicable legislation and donor requirements. Where possible, the Foundation shall ensure that monitoring results can be used publicly, subject to safety requirements and the protection of confidential information.

12.5. The first instalment shall be disbursed after the agreement has been signed and the agreed preliminary conditions have been fulfilled.

13. Financial Management and Eligible Expenses

13.1. Subgrant funds shall be used exclusively for the approved objectives and activities.

13.2. Eligible expenses may include:

  • Remuneration for coordinators, researchers and monitoring specialists;
  • Travel to regions, transportation and accommodation;
  • Organisation of meetings, consultations and public discussions;
  • Collection, verification and analysis of information;
  • Preparation and dissemination of reports;
  • Translation, editing and publication of materials;
  • Communications, internet access and necessary digital tools;
  • Rental of premises and equipment;
  • Training and capacity development for participants;
  • Reasonable administrative expenses directly related to the implementation of the initiative;
  • Other expenses included in the approved budget and permitted by the donor.

13.3. Expenses unrelated to the objectives of the subgrant, as well as expenses prohibited by donor conditions or legislation, shall not be funded.

13.4. The recipient shall maintain records of transactions under the subgrant and ensure that expenses financed under the relevant agreement can be identified.

13.5. The Foundation shall establish requirements for supporting documents in the agreement, taking into account the legislation of the Kyrgyz Republic, the nature of the expenses and donor conditions.

13.6. Where a standard document cannot be obtained for a particular expense, the Foundation may consider alternative supporting evidence only where permitted by applicable rules. The decision and its justification shall be documented.

13.7. Budget amendments and reallocations of funds shall be permitted within the authority established by the agreement and donor conditions. Material changes shall be approved in advance in accordance with the established procedure.

13.8. Unspent funds, funds used for unauthorised purposes and funds subject to recovery under the agreement shall be handled in accordance with the agreement, donor conditions and applicable legislation.

14. Disbursement of Funds

14.1. A subgrant may be disbursed in a single payment or in several instalments.

14.2. The payment schedule shall be determined taking into account the amount of the subgrant, the duration of the initiative, the recipient’s needs and donor requirements.

14.3. Subsequent instalments may be conditional upon submission and acceptance of an interim report, achievement of agreed results or fulfilment of other contractual requirements.

14.4. Where necessary, the Foundation may provide advance payments if permitted by donor conditions and supported by appropriate contractual and financial controls.

14.5. The Foundation shall not require recipients to provide co-financing unless this is stipulated by the conditions of the specific programme. Where co-financing is required, its amount, acceptable forms and verification procedure shall be specified in the call for proposals.

15. Monitoring Subgrant Implementation

15.1. The Foundation shall monitor subgrant implementation to verify achievement of objectives, compliance with deadlines, proper use of funds and identification of potential risks.

15.2. Monitoring may include:

  • Review of interim and final reports;
  • Discussions with the recipient about implementation progress;
  • Examination of a sample of supporting financial documents;
  • Analysis of monitoring results;
  • Visits to activities or locations where the initiative is implemented;
  • Consultations with participants and representatives of local communities;
  • Verification of the implementation of recommendations and correction of identified deficiencies.

15.3. The scope of monitoring shall be determined in proportion to the subgrant amount, the nature of the activities, identified risks and donor requirements.

15.4. Where problems are identified, the Foundation shall first seek to ensure that deficiencies are addressed in a timely manner through consultations, written recommendations and an agreed corrective action plan.

15.5. Where there are reasonable indications of fraud, a material breach of the agreement, misuse of funds or a threat to safety, the Foundation may take measures provided for in the agreement and donor conditions, including suspending payments and conducting additional verification.

16. Recipient Reporting

16.1. Recipients shall submit substantive and financial reports within the deadlines and using the formats established in the agreement.

16.2. A substantive report shall generally include:

  • Description of activities completed;
  • Results achieved;
  • Information on the participation of local communities;
  • Main monitoring findings;
  • Problems and limitations identified;
  • Materials and recommendations prepared;
  • Information on the dissemination of results;
  • A plan for further action, where required by the programme.

16.3. The financial report shall provide details of expenses incurred against the approved budget, remaining funds and deviations from the original plan.

16.4. Supporting documents shall be attached to the financial report to the extent required by the agreement and applicable requirements.

16.5. The Foundation may request explanations and additional documents necessary to verify reports, provided that confidentiality and safety requirements are respected.

16.6. Where omissions or errors are identified, the Foundation shall establish a reasonable deadline for correcting the report.

16.7. A subgrant shall be closed after the final reports have been accepted, financial obligations have been settled and other requirements stipulated in the agreement have been fulfilled.

17. Independence of Public Monitoring

17.1. Subgrants are intended to produce reliable public monitoring results, not to achieve predetermined positive or negative conclusions.

17.2. The recipient shall independently determine its findings on the basis of collected and verified data, agreed objectives, the applicable methodology and professional standards.

17.3. The Foundation shall not require the recipient to change substantiated findings solely because they are critical of a project, donor, contractor or public authority.

17.4. At the same time, the recipient shall comply with requirements concerning information accuracy, fact-checking, responsible presentation of findings and protection of sources.

17.5. If a donor or other interested party disagrees with monitoring results, such disagreement alone shall not constitute grounds for terminating funding. Disputed matters shall be considered in accordance with the agreement and the principles of good faith.

18. Protection of Participants and Personal Data

18.1. Recipients shall take reasonable measures to protect persons involved in monitoring, including residents of affected areas, applicants, witnesses, informants and representatives of local communities.

18.2. The collection of personal data shall be limited to the minimum necessary. Before collecting and processing data, the purpose, legal basis, access arrangements, storage procedures and information security measures shall be determined.

18.3. Personal data that make monitoring participants identifiable may be published only where there is a lawful basis and any necessary consent has been obtained, where required, and provided that publication does not create an unjustified risk to the persons concerned.

18.4. If publication of a name, contact details, photograph or other identifying information could lead to persecution, pressure or other harm, the recipient shall consider anonymising the information.

18.5. When conducting interviews, consultations and collecting testimonies, recipients shall clearly inform participants about the purpose of the activity, the possible use of the information and the limits of confidentiality.

18.6. The Foundation may require specific methods of information collection and dissemination to be reconsidered if they create unjustified risks to participants, without unreasonably interfering with the independent findings of the monitoring.

19. Prevention of Fraud and Misuse of Funds

19.1. The Foundation adheres to a zero-tolerance principle towards fraud, corruption, bribery, misappropriation of funds, document forgery and the deliberate provision of false information.

19.2. The recipient shall promptly inform the Foundation of any material violations identified, suspected misuse of funds and other circumstances specified in the agreement.

19.3. The Foundation shall provide a means for reporting suspected violations safely. Reports shall be considered objectively and confidentially to the extent permitted by law, without retaliation against individuals who report concerns in good faith.

19.4. Where reasonable suspicions exist, the Foundation shall conduct a review, document its findings and take proportionate measures in accordance with the agreement, donor conditions and applicable legislation.

19.5. Confirmed violations may result in the suspension of payments, a requirement to remedy the violations, termination of the agreement, recovery of funds and notification of the donor or competent authorities where necessary or required by applicable rules.

20. Complaints and Dispute Resolution

20.1. Applicants and other interested parties may report suspected violations of the competition procedure, conflicts of interest, discrimination, improper influence on selection results or other breaches of this Policy.

20.2. Information on how to submit complaints and the relevant contact person shall be published in the call for proposals.

20.3. Complaints shall be considered impartially. If a complaint concerns a person responsible for making a decision, that person shall not be the sole reviewer of a complaint concerning their own actions.

20.4. Where necessary, the Foundation shall appoint an independent person to review a complaint.

20.5. The Foundation shall record the date a complaint is received, its subject matter, the actions taken and the outcome of the review. A response shall be provided to the complainant within a reasonable period, taking into account the complexity of the matter and donor requirements.

20.6. The submission of a complaint in good faith shall not, in itself, constitute grounds for discrimination, retaliation or exclusion of the applicant from future calls for proposals.

21. Documentation and Record Retention

21.1. The Foundation shall maintain documentation for each subgrant, including:

  • The call for proposals and competition documentation;
  • Applications received;
  • Assessment results and Selection Committee minutes;
  • Conflict of interest declarations;
  • The decision to award the subgrant;
  • The signed agreement and approved budget;
  • Documents confirming the transfer of funds;
  • Substantive and financial reports;
  • Monitoring and verification materials;
  • Correspondence concerning material matters;
  • Documents relating to amendments and subgrant closure.

21.2. Documents shall be retained for the periods established by the legislation of the Kyrgyz Republic, donor agreements and the Foundation’s internal rules, applying the longest period required by the applicable provisions.

21.3. Access to documents shall be restricted to the extent necessary to protect personal data, confidential information and participant safety.

21.4. The Foundation shall ensure that inspections and audits provided for by the agreement and donor conditions can be conducted.

22. Public Disclosure and Transparency

22.1. The Foundation shall seek to ensure transparency in subgranting programmes by publishing information about calls for proposals, programme objectives, selection results and achievements.

22.2. Published information about recipients may include the name of the organisation or initiative, region, purpose of the subgrant, implementation period, funding amount and main results, where permitted by law and donor conditions.

22.3. Information whose publication could threaten participants’ safety, reveal confidential sources or violate personal data protection requirements shall not be publicly disclosed to the relevant extent.

22.4. Recipients may acknowledge support from the Foundation and the donor in project materials in accordance with agreed acknowledgement requirements and rules governing the use of logos.

23. Responsibilities and Authority

23.1. The Director of the Foundation shall provide overall management of subgranting programmes, approve competition documentation within the scope of their authority, sign agreements, organise financial control and ensure compliance with this Policy.

23.2. The finance officer or accountant shall, within the scope of their duties, be responsible for checking financial documents, recording transactions, monitoring financial reporting and preparing financial information.

23.3. The programme coordinator shall be responsible for organising the competition, communicating with recipients, monitoring activities and reviewing substantive reports.

23.4. The Selection Committee shall be responsible for the objective assessment of applications, documentation of results and disclosure of conflicts of interest.

23.5. Recipients shall be responsible for fulfilling their contractual obligations, ensuring the accuracy of the information they provide, using funds for their intended purposes and complying with applicable requirements.

23.6. The Foundation may engage external experts, auditors and consultants to assess applications, monitor implementation and verify reports, subject to confidentiality and conflict of interest rules.

24. Review and Amendment of the Policy

24.1. This Policy shall be reviewed in the event of material changes in legislation, donor requirements, the Foundation’s governance structure or the practices used to implement subgranting programmes.

24.2. Amendments to this Policy shall be approved by the authorised body of the Foundation in accordance with its Charter and internal procedures.

24.3. Where donor requirements establish additional procedures for a specific programme, the Foundation shall approve the relevant supplements, instructions or annexes to this Policy.

24.4. This Policy shall enter into force on the date of its approval, unless otherwise provided for in the approval decision.

Annex 1. Recommended Set of Documents for a Subgranting Programme

  1. Call for proposals.
  2. Subgrant application form.
  3. Budget form.
  4. Application assessment form and selection criteria.
  5. Conflict of interest declaration for Selection Committee members.
  6. Applicant conflict of interest declaration form.
  7. Subgrant agreement template.
  8. Interim substantive reporting form.
  9. Final substantive reporting form.
  10. Financial reporting form.
  11. Checklist for verifying documents and expenses.
  12. Monitoring visit or verification form.
  13. Complaint submission and review procedure.
  14. Subgrant closure form.

Annex 2. Minimum Stages of the Subgrant Award Process

  1. Confirmation of funding and eligibility to provide subgrants.
  2. Approval of the competition conditions and assessment criteria.
  3. Public announcement of the call for proposals.
  4. Receipt and registration of applications.
  5. Verification of compliance with formal requirements.
  6. Assessment of applications and documentation of results.
  7. Decision on the selection of recipients.
  8. Verification of required documents and conclusion of agreements.
  9. Disbursement of funds.
  10. Implementation support and monitoring.
  11. Receipt and review of reports.
  12. Subgrant closure and organisation of records.

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