GFO Issue 462, Article Number: 10
ABSTRACT
The 53ᵉ Board meeting of the Global Fund took place on May 7, 8, and 9. A thorough examination of integrity and adherence to core ethical values was one of the subjects covered. This article will provide a concise overview of the topics covered at the 53ᵉ board meeting about the Global Fund ethics and integrity program.
Unethical behavior, including fraud, corruption, and abuse of power, is becoming more prevalent in the Global Fund's organization of everyday tasks. These practices harm Global Fund recipients, hinder access to healthcare, and damage the organization's reputation during logistical challenges, health crises, and geopolitical conflicts.
According to the annual opinion of the Global Fund Chief Risk Officer, the heightened organizational risk brought on by crises, global instability, and the deprioritization of public health funding impacts board members, staff, vendors, and implementation partners. Delays in delivering supplies and medications are impacting the Global Fund's main objective of saving lives, necessitating a reaffirmation of ethical governance.
In 2024, the Global Fund's Ethics Office updated its strategic action plan and started a three-year project aimed at raising ethical standards across the organization. Without a focus on ethics and integrity, 2024 could have ended in controversy, misunderstanding, and reputational damage to the Global Fund.
Without updated policies, training, and moral leadership, misconduct would have flourished in regions with weak healthcare systems.
The ability to respond to modern challenges
Strengthening the ethics program
In 2024, the Global Fund's Ethics Office launched a three-year project to improve ethical standards across the organization. The goal was to integrate integrity into all operational levels, from risk management to strategic decision-making. The Ethics & Compliance Initiative's High-Quality Program Measurement Framework was used to evaluate ethical performance. Additionally, the Ethics Officer provided the Board with an annual opinion on ethics and integrity based on internal operations, leadership interviews, and reports from the Office of the Inspector General and the Risk Department.
In order to promote organizational resilience, a strong ethical culture was established within organization from three main elements such as: clear standards of conduct, learning for understanding and accountability these elements
form the foundation of the Global Fund's strategy
Clear standards of conduct:
In 2024, the Global Fund began updating its Employee Code of Conduct to strengthen organizational values, establish clear guidelines for employee conduct, and improve the code's applicability, usefulness, and accessibility. Throughout this process, the Ethics Office interacted with the Secretariat and worked closely with key stakeholders.
The updated Code will take effect in 2025, together with additional resources and guidelines.
Learning for understanding:
Throughout 2024, the Ethics Office strengthened its cooperation with the Office of the Inspector General (OIG) and provided training on ethical behavior and the mitigation of significant E&I risks to a broad spectrum of stakeholders.
The following will be added to the training program in 2025:
Provide training on ethical conduct and mitigating key E&I risks
- Collaborate with OIG, GMD and CRG on fraud prevention and PSEAH
- Continue to provide learning opportunities to staff, implementers, CCMs, and governance officials
Accountability:
In 2024, as part of broader efforts to promote a "speak up" culture, the Ethics Office began a comprehensive review of the Global Fund's internal justice mechanism (IJM) in close coordination with the Chief Human Resources Officer, Chief of Staff, and General Counsel.
In 2025, the Ethics Office will build on this work by implementing significant enhancements identified in the review, including measures to strengthen protections against retaliation for individuals who openly report problems.
Mitigating key ethics risks to safeguard resources dedicated to health
Avoiding and managing conflicts of interest (COI)
In 2024, the Ethics Office promoted transparency and conflict of interest management by implementing the Disclosure of Interest (DOI) program.
A total of 83 COI instances were evaluated, and 99% of governance officials participated.
Support came in the form of COI evaluations, DOI campaigns, and tailored guidance for key governance bodies.
Additionally, the Office raised awareness of COI risks during meetings and onboarding.
In 2025, the primary areas of focus will be targeted awareness campaigns, technological utilization, and procedural improvements.
Protection from sexual exploitation, abuse, And harassment (PSEAH)
The Global Fund is committed to eradicating malaria, HIV, and tuberculosis by providing people-centered services and fostering secure and encouraging environments in its collaborations.
While it is impossible to completely eliminate the risk of sexual exploitation, abuse, and harassment (SEAH), the Global Fund is committed to minimizing risks and taking appropriate action.
In 2024, the Global Fund increased its efforts to prevent and address SEAH by conducting the following actions:
- 793 people from various stakeholder groups participated in capacity-building and safer programming workshops in Nigeria, Côte d'Ivoire, Uganda, Zimbabwe, and Malaysia.
- An online SEAH resource library was created, and 66 PRs from 26 countries were evaluated in capacity evaluations and resource development.
- To increase knowledge of SEAH hazards and reporting procedures, campaigns were piloted in Ghana, Kenya, and the Philippines through Locally Owned Communication Campaigns.
- Technical assistance for investigations and victim care, as well as collaboration with the Office of the Inspector General, was organized as part of a trauma-informed, survivor-centered response.
With 22 victims assisted, 39 new SEAH instances were recorded in 2024, demonstrating greater awareness and confidence in the reporting system. This represents a 34.5% increase from 2023.
The main priorities for 2025 include completing technical assistance in high-priority countries, engaging with Francophone Africa, incorporating PSEAH risk mitigation into grant-making, promoting culturally sensitive approaches, and expanding online resources for partners.
The Global Fund is committed to creating safer environments for all its collaborators.
Promoting integrity in its operations and funded programs
The Ethics Office encourages ethical behavior and operational integrity through a number of targeted activities such as integrity due diligence (IDD), fraud and corruption, country coordinating mechanisms (CCM).
integrity due diligence (IDD) framework: The Ethics Office uses the IDD Framework to assess and manage counterparty integrity risks.
In 2024, IDD was conducted for 2,714 individuals, 794 organizations, and 184 government candidates.
Additionally, enhanced IDD was performed for significant transactions and suppliers.
The findings influenced mitigation tactics to prevent reputational risks.
In 2025, integrity concerns will be incorporated into the Global Fund Capacity Assessment and Integrated Risk Management instruments.
combating fraud & corruption: The Ethics Office collaborates with stakeholders and the OIG to combat corruption and fraud.
In 2024, efforts were made to integrate fraud risk reduction into grant design, focusing on results and performance.
In 2025, these efforts will continue with a focus on providing technological support and managing fraud risk.
strengthening ethical operations of country coordinating mechanisms (CCM): by improving moral conduct, judgment, and conflict of interest management.
In 2024, 15 CCM ethics officers received support and technical assistance to encourage ethical cultures.
In 2025, the primary focus will be on strategic actions to maintain integrity and reduce ethical risks, particularly emphasizing sustainability and strengthening CCM ethics committees and focal points.
Stakeholder feedback from the Global Fund board meeting
Stakeholders commended the Ethics Office for its significant contributions to the Global Fund's ethics protocols, institutional maturity, strategy, and risk management. They recognized the office's significant progress.
However, several stakeholders expressed concern that the current budget allocation may not be sufficient for developing the organization's governance structures. Of particular concern is the absence of comprehensive criteria for incorporating gender, intersectionality, poverty, and human rights into Global Fund assessments. While some progress has been made, this work remains incomplete and must be prioritized for completion by 2025 to ensure assessments are inclusive, equitable, and representative of various lived experiences.
Other stakeholders emphasized that significant concerns regarding ethics and integrity remain, especially with regard to human rights and the shrinking civic space.
The Ethics Office and the Global Fund were urged to take a more proactive approach to addressing systemic issues hindering community and key population engagement, especially in financially limited situations.
in fact, positive steps were noted in areas such as:
- Strengthening safeguards against sexual exploitation, abuse, and harassment (PSEAH),
- Enhancing conflict of interest management, and
- Building an ethical organizational culture.
However, despite these advancements, significant residual risks persist, especially in:
- PSEAH prevention and enforcement,
- Governance at the Country Coordinating Mechanism (CCM) level, and
- Accountability of grant implementers.
Recommendations from stakeholders
In order to represent countries with vulnerable populations, the stakeholders emphasized the following needs:
- Full implementation of strengthened SEAH and ethics risk mitigation measures,
- Consistent application of ethical standards from the Secretariat to CCMs and frontline implementers,
- Deeper regional ethics risk analysis to inform more targeted interventions, and
- Greater investment in: localized and accessible reporting mechanisms, ethics capacity at the CCM level, and integration of ethics considerations during grant-making.
- Embedding rights-based approaches,
- Enhancing whistleblower protections,
- Ensuring robust support for community-led monitoring and accountability mechanisms as part of broader ethical risk mitigation efforts.
Additionally, tracking misconduct trends and mitigation progress at the regional or stakeholders’ level was recommended to sharpen future prevention strategies.
All in all, stakeholders reaffirmed their commitment to collaborating with the Ethics Office to uphold integrity, accountability, and ethical excellence across all levels of Global Fund-supported programs.
Unethical behavior, including fraud, corruption, and abuse of power, is becoming more prevalent in the Global Fund's organization of everyday tasks. These practices harm Global Fund recipients, hinder access to healthcare, and damage the organization's reputation during logistical challenges, health crises, and geopolitical conflicts.
According to the annual opinion of the Global Fund Chief Risk Officer, the heightened organizational risk brought on by crises, global instability, and the deprioritization of public health funding impacts board members, staff, vendors, and implementation partners. Delays in delivering supplies and medications are impacting the Global Fund's main objective of saving lives, necessitating a reaffirmation of ethical governance.
In 2024, the Global Fund's Ethics Office updated its strategic action plan and started a three-year project aimed at raising ethical standards across the organization. Without a focus on ethics and integrity, 2024 could have ended in controversy, misunderstanding, and reputational damage to the Global Fund.
Without updated policies, training, and moral leadership, misconduct would have flourished in regions with weak healthcare systems.
The ability to respond to modern challenges
Strengthening the ethics program
In 2024, the Global Fund's Ethics Office launched a three-year project to improve ethical standards across the organization. The goal was to integrate integrity into all operational levels, from risk management to strategic decision-making. The Ethics & Compliance Initiative's High-Quality Program Measurement Framework was used to evaluate ethical performance. Additionally, the Ethics Officer provided the Board with an annual opinion on ethics and integrity based on internal operations, leadership interviews, and reports from the Office of the Inspector General and the Risk Department.
In order to promote organizational resilience, a strong ethical culture was established within organization from three main elements such as: clear standards of conduct, learning for understanding and accountability these elements
form the foundation of the Global Fund's strategy
Clear standards of conduct:
In 2024, the Global Fund began updating its Employee Code of Conduct to strengthen organizational values, establish clear guidelines for employee conduct, and improve the code's applicability, usefulness, and accessibility. Throughout this process, the Ethics Office interacted with the Secretariat and worked closely with key stakeholders.
The updated Code will take effect in 2025, together with additional resources and guidelines.
Learning for understanding:
Throughout 2024, the Ethics Office strengthened its cooperation with the Office of the Inspector General (OIG) and provided training on ethical behavior and the mitigation of significant E&I risks to a broad spectrum of stakeholders.
The following will be added to the training program in 2025:
Provide training on ethical conduct and mitigating key E&I risks
- Collaborate with OIG, GMD and CRG on fraud prevention and PSEAH
- Continue to provide learning opportunities to staff, implementers, CCMs, and governance officials
Accountability:
In 2024, as part of broader efforts to promote a "speak up" culture, the Ethics Office began a comprehensive review of the Global Fund's internal justice mechanism (IJM) in close coordination with the Chief Human Resources Officer, Chief of Staff, and General Counsel.
In 2025, the Ethics Office will build on this work by implementing significant enhancements identified in the review, including measures to strengthen protections against retaliation for individuals who openly report problems.
Mitigating key ethics risks to safeguard resources dedicated to health
Avoiding and managing conflicts of interest (COI)
In 2024, the Ethics Office promoted transparency and conflict of interest management by implementing the Disclosure of Interest (DOI) program.
A total of 83 COI instances were evaluated, and 99% of governance officials participated.
Support came in the form of COI evaluations, DOI campaigns, and tailored guidance for key governance bodies.
Additionally, the Office raised awareness of COI risks during meetings and onboarding.
In 2025, the primary areas of focus will be targeted awareness campaigns, technological utilization, and procedural improvements.
Protection from sexual exploitation, abuse, And harassment (PSEAH)
The Global Fund is committed to eradicating malaria, HIV, and tuberculosis by providing people-centered services and fostering secure and encouraging environments in its collaborations.
While it is impossible to completely eliminate the risk of sexual exploitation, abuse, and harassment (SEAH), the Global Fund is committed to minimizing risks and taking appropriate action.
In 2024, the Global Fund increased its efforts to prevent and address SEAH by conducting the following actions:
- 793 people from various stakeholder groups participated in capacity-building and safer programming workshops in Nigeria, Côte d'Ivoire, Uganda, Zimbabwe, and Malaysia.
- An online SEAH resource library was created, and 66 PRs from 26 countries were evaluated in capacity evaluations and resource development.
- To increase knowledge of SEAH hazards and reporting procedures, campaigns were piloted in Ghana, Kenya, and the Philippines through Locally Owned Communication Campaigns.
- Technical assistance for investigations and victim care, as well as collaboration with the Office of the Inspector General, was organized as part of a trauma-informed, survivor-centered response.
With 22 victims assisted, 39 new SEAH instances were recorded in 2024, demonstrating greater awareness and confidence in the reporting system. This represents a 34.5% increase from 2023.
The main priorities for 2025 include completing technical assistance in high-priority countries, engaging with Francophone Africa, incorporating PSEAH risk mitigation into grant-making, promoting culturally sensitive approaches, and expanding online resources for partners.
The Global Fund is committed to creating safer environments for all its collaborators.
Promoting integrity in its operations and funded programs
The Ethics Office encourages ethical behavior and operational integrity through a number of targeted activities such as integrity due diligence (IDD), fraud and corruption, country coordinating mechanisms (CCM).
integrity due diligence (IDD) framework: The Ethics Office uses the IDD Framework to assess and manage counterparty integrity risks.
In 2024, IDD was conducted for 2,714 individuals, 794 organizations, and 184 government candidates.
Additionally, enhanced IDD was performed for significant transactions and suppliers.
The findings influenced mitigation tactics to prevent reputational risks.
In 2025, integrity concerns will be incorporated into the Global Fund Capacity Assessment and Integrated Risk Management instruments.
combating fraud & corruption: The Ethics Office collaborates with stakeholders and the OIG to combat corruption and fraud.
In 2024, efforts were made to integrate fraud risk reduction into grant design, focusing on results and performance.
In 2025, these efforts will continue with a focus on providing technological support and managing fraud risk.
strengthening ethical operations of country coordinating mechanisms (CCM): by improving moral conduct, judgment, and conflict of interest management.
In 2024, 15 CCM ethics officers received support and technical assistance to encourage ethical cultures.
In 2025, the primary focus will be on strategic actions to maintain integrity and reduce ethical risks, particularly emphasizing sustainability and strengthening CCM ethics committees and focal points.
Stakeholder feedback from the Global Fund board meeting
Stakeholders commended the Ethics Office for its significant contributions to the Global Fund's ethics protocols, institutional maturity, strategy, and risk management. They recognized the office's significant progress.
However, several stakeholders expressed concern that the current budget allocation may not be sufficient for developing the organization's governance structures. Of particular concern is the absence of comprehensive criteria for incorporating gender, intersectionality, poverty, and human rights into Global Fund assessments. While some progress has been made, this work remains incomplete and must be prioritized for completion by 2025 to ensure assessments are inclusive, equitable, and representative of various lived experiences.
Other stakeholders emphasized that significant concerns regarding ethics and integrity remain, especially with regard to human rights and the shrinking civic space.
The Ethics Office and the Global Fund were urged to take a more proactive approach to addressing systemic issues hindering community and key population engagement, especially in financially limited situations.
in fact, positive steps were noted in areas such as:
- Strengthening safeguards against sexual exploitation, abuse, and harassment (PSEAH),
- Enhancing conflict of interest management, and
- Building an ethical organizational culture.
However, despite these advancements, significant residual risks persist, especially in:
- PSEAH prevention and enforcement,
- Governance at the Country Coordinating Mechanism (CCM) level, and
- Accountability of grant implementers.
Recommendations from stakeholders
In order to represent countries with vulnerable populations, the stakeholders emphasized the following needs:
- Full implementation of strengthened SEAH and ethics risk mitigation measures,
- Consistent application of ethical standards from the Secretariat to CCMs and frontline implementers,
- Deeper regional ethics risk analysis to inform more targeted interventions, and
- Greater investment in: localized and accessible reporting mechanisms, ethics capacity at the CCM level, and integration of ethics considerations during grant-making.
- Embedding rights-based approaches,
- Enhancing whistleblower protections,
- Ensuring robust support for community-led monitoring and accountability mechanisms as part of broader ethical risk mitigation efforts.
Additionally, tracking misconduct trends and mitigation progress at the regional or stakeholders’ level was recommended to sharpen future prevention strategies.
All in all, stakeholders reaffirmed their commitment to collaborating with the Ethics Office to uphold integrity, accountability, and ethical excellence across all levels of Global Fund-supported programs.
