11.

Donor and Government Compliance

11.1 Donor Compliance

Most government or institutional donors have established their own procurement policies.
Compliance with those policies is mandatory under the terms of their grants or contracts.
Failure to comply with donor regulations may result in unnecessary delays and disallowed
costs which may be detrimental not only to your Country Program but to the IRC overall.

Donor regulations take precedence over IRC policies and processes unless the Country
Program elects to undertake a more rigorous process. These issues should be discussed in
Grant Opening Meetings.

Support for donor compliance is provided by in-country grants, finance and senior
management staff, the IRC NY Grants Unit and the IRC UK Compliance Unit. As donor
regulations are periodically updated, and new grant agreements may contain additional grant
or country-specific procurement and supplier contracting requirements, it is imperative that
Supply Chain staff work closely with relevant staff to ensure compliance.

The rules for many donors have changed over time but the most recent rules only apply to
grants signed since their publication, so check the contract award procedures for the grant
contract in question.

The information below is a brief overview of major IRC donor regulations as they apply to
most procurement situations. Restrictions, regulations and requirements may vary by
specific awards, causing differences in requirements between grants funded by the same
agency.

ECHO

The documented procedures provided in this manual, subject to additional regulations on

order splitting, pharmaceuticals and medical procurement, and the procurement of food, are
sufficient to ensure compliance with ECHOs regulations.

Please note that urgent actions have a very specific meaning related to the type of call and
are not simply emergencies. Country Offices should be extremely cautious about committing
to procurement for ECHO when time is going to be an issue. If items cannot be procured
early enough to be used directly for program delivery and therefore an incurred cost, it will
not be an eligible cost.

ECHO requires that for the award of contracts whose estimated value exceeds 60,000, the
Humanitarian Organization shall have in place written procurement procedures to ensure
proportionality between the procedures to be followed for awarding contracts and the value
of those contracts. Closed, negotiated, or restricted procurement procedures based on less

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