2. Legislative and policy framework for grants administration

A threshold issue in the effective administration of the expenditure of public money is establishing the substantive nature of a transaction and, accordingly, the legislative and policy requirements that must be complied with.

Key Points

The grants policy framework promotes transparent, accountable and cost-effective grants administration through a combination of legislative and policy requirements and associated guidance which form the context in which programs are to be administered. This framework is aimed at promoting a consistently high standard in grants administration to the benefit of applicants, government and the broader community. Key considerations are that:

• grant programs occur within the context of the overarching obligation to make proper use of Commonwealth resources. In this context, consideration of alternative financial arrangements will assist in establishing whether a grant is the most appropriate and cost-effective financial arrangement to achieve the relevant government objective;
• the grants policy framework applies to all spending proposals that satisfy the principles-based definition of a grant set out in the FMA Regulations, regardless of the means by which the program is established or a proposal is brought forward for consideration; and
• grant approval and administration processes that comply with the statutory and mandatory policy requirements set out in the FMA Regulations and CGGs, as well as observing the sound practice guidance set out in the CGGs, are considerably more likely to see the best applications selected for funding, as well as enabling effective administration of approved funding for the least effort and cost.

2.1 Framework for the administration of grant programs

Ministers, agencies and officials operate within an environment of legislation and government policy. Within this broad context, the financial management framework consists of the legislation and policy governing the management of Commonwealth resources. The grants policy framework introduced from 1 July 2009 is a subset of the financial management framework.

Agency Chief Executives are required to provide the Minister for Finance and Deregulation with an annual Certificate of Compliance certifying as to his or her agency's compliance with the financial management framework and reporting any instances of non-compliance. In that context, it is expected that Chief Executives will ensure that their agency has sufficient processes and controls in place to provide reasonable confidence that officials are complying with the financial management framework.[12]

It is a matter for agencies to determine their specific practices and procedures for grants administration, provided they are consistent with the grants policy framework, incorporating the CGGs and financial management framework. This will usually be achieved through the Chief Executive's Instructions (CEIs) issued by the agency's Chief Executive[13], other general policies and procedures established within the relevant agency in relation to financial management, and the specific guidelines and administrative arrangements established for individual grant programs. The CEIs may:

• interpret the grants policy framework and the wider financial management framework, focussing on the agency's particular needs; and
• provide primary operational instructions to agency officials in carrying out their duties related to grants administration, in a way that is tailored to the agency's particular circumstances and needs.

Ensuring that the relevant requirements are well understood and effectively incorporated into the design and administration of any grant program is essential in order for Ministers, agencies and officials to fulfil their obligations in a transparent, accountable and cost-effective manner. In turn, adherence to these obligations is expected to deliver high quality grants administration and promote the achievement of program and broader policy objectives.

2.1.1 Financial management framework

The FMA Act provides a framework for the proper management of public money.[14] Most of the detailed rules regarding the expenditure of public money are set out in the FMA Regulations made under the Act.[15] The FMA Act and associated Regulations apply to Ministers and officials in Australian Government Departments of State, Departments of the Parliament and agencies prescribed in the FMA Regulations.

Section 44 of the FMA Act sets out an overarching requirement applying to all aspects of an agency's resource management, which requires that:

A Chief Executive must manage the affairs of the Agency in a way that promotes proper use of the Commonwealth resources for which the Chief Executive is responsible.

Section 44(3) of the Act defines 'proper use' as:

efficient, effective and ethical use that is not inconsistent with the policies of the Commonwealth.

In fulfilling their obligations under section 44 of the FMA Act, Chief Executives must comply with the Act, FMA Regulations, Finance Minister's Orders, Special Instructions and any other law (FMA Act s.44(2)).

Part 4 of the FMA Regulations, Commitments to spend public money, sets out a hierarchy of requirements that must each be satisfied, in the appropriate sequence, in order for a commitment to spend public money to be lawfully entered into. These requirements regulate the process to be applied in determining whether or not to approve a spending proposal, including those relating to grants, and control the capacity for any person to lawfully enter into any arrangement under which public money may become payable. The general requirements that relate to all spending proposals are as follows:

• Regulation 3 defines a 'spending proposal' as a proposal that could lead to the creation of a contract, agreement or arrangement under which public money is, or may become, payable;
• in concert, Regulations 3 and 11 define who has authority to act as an approver of a spending proposal and in what circumstances;
• under Regulation 10, a person who otherwise has authority to act as an approver is not able to lawfully approve a spending proposal that involves expenditure for which there is not sufficient uncommitted appropriation available unless the Finance Minister (or delegate) has authorised the approver in writing to give such an approval;
• Regulation 9 prohibits an approver from approving a spending proposal unless satisfied, after undertaking reasonable inquiries, that giving effect to the proposal would be a proper use of Commonwealth resources (within the meaning given by subsection 44(3) of the Act);
• under Regulation 12, approvers must make a written record of the factual terms of the approval, either at the time of giving approval or as soon as practicable after that; and
• Regulation 13 prohibits any person, whether a Minister, official or any other person, from entering into a contract, agreement or arrangement under which public money is, or may become, payable unless a relevant spending proposal has been properly approved in accordance with Regulation 9 (including that, where necessary, the Regulation 9 approval was properly authorised for the purposes of Regulation 10).

Additional FMA Regulations specific to grants administration

In addition to the general requirements relating to the expenditure of public money, the introduction of the new framework for grants administration involved the specification of additional statutory requirements, as follows:

• Regulation 3A identifies which financial arrangements will be subject to the grants policy framework. Regulation 3A(1) defines the characteristics that will result in a payment being considered a 'grant' for the purposes of the Regulations and the CGGs, while Regulation 3A(2) lists a number of arrangements that are specifically taken not to be grants for the purposes of the Regulations and CGGs;
• Regulation 7A provides authority for the Finance Minister to issue the CGGs, and stipulates that officials performing duties in relation to grants administration must act in accordance with the CGGs; and
• Regulation 12 now includes an additional requirement that, where the spending proposal relates to a grant, approvers must also make a written record of the basis on which they are satisfied that the spending proposal complies with Regulation 9.

2.1.2 Policy requirements

As noted, agencies are required to make efficient, effective and ethical use of Commonwealth resources in a manner that is not inconsistent with the policies of the Commonwealth, with the same requirement applying to approvers of spending proposals. In this respect, the CGGs stipulate that the policy requirements that must be complied with in administering a grant program include:

• the CGGs, which are the core policy of the Commonwealth relating to grants administration;
• applicable policies and legislation of the Commonwealth[16];
• the guidelines applying to a granting activity; and
• grant-specific process requirements decided by government.[17]

Accordingly, the grants policy framework sits within the general financial management framework, but also requires grants administration to take appropriate account of the broader policy context (see Figure 2).

Figure 2

Grants policy framework within the context of the general financial framework and Australian Government policy

Source: ANAO analysis.

Mandatory policy requirements under the CGGs

The CGGs identify a number of mandatory process, decision-making and reporting requirements for both Ministers and officials involved in grants administration, as set out in Figure 3.

Figure 3

Summary of mandatory policy requirements under the Commonwealth Grant Guidelines

Ministerial requirements	Agency requirements
CGG 3.19: Where a Minister exercises the role of a financial approver relating to a grant, they will not approve a grant without first receiving agency advice on the merits of the proposed grant.	CGG 3.23: Agencies are responsible for advising Ministers on the requirements of the CGGs, and must take appropriate and timely steps to do so where a Minister exercises the role of financial approver in grants administration.
CGG 3.20: Each time a Minister who is a Member of the House of Representatives approves a grant in respect to their own electorate, the Minister will write to the Finance Minister advising of the details. If the agency recommended that the grant be approved, it will be sufficient to provide the Finance Minister with a copy of the correspondence advising the recipient of the grant. If there is no correspondence, the Minister must write to the Finance Minister advising of the decision as soon as practicable after it is made. If the approval related to a grant that the agency had recommended be rejected, the Minister's written advice to the Finance Minister must also include a brief statement of the basis for the approval.	CGG 3.15: Officials involved in grants administration must ensure that they: always take care to behave in accordance with the law (including regulations), government policy, agency rules (for example, CEIs) and with applicable funding agreements; keep commercially sensitive information secure and never use it for personal gain or to prejudice grants administration processes; disclose information that the Government requires to be notified; and disclose to their agency any form of current or prospective personal interest that might create a conflict of interest in grants administration.
CGG 3.21: Approval of grants that the agency recommended be rejected: By 31 March each year, Ministers must provide the Finance Minister with a report on all instances in the preceding calendar year in which the Minister decided to approve a grant which the agency had recommended be rejected, including a brief statement of the basis of the approval of each grant. The annual report must include any such grants approved in the Minister's own electorate previously advised to the Finance Minister in accordance with CGG 3.20.	An agency must publish, on its website, information on its individual grants no later than seven working days after the funding agreement for the grant takes effect. Other requirements apply where agencies determine that publishing grant information in accordance with the CGGs is contrary to legislative requirements, the specific terms of a funding agreement or could adversely affect the achievement of government policy outcomes. The grant information should be retained on the website for at least two financial years. Where this is not done, the agency must document the reasons for that.
Other mandatory process requirements likely to involve both Ministers and agencies, having regard for Ministerial policy responsibility:
CGG 3.24: Agencies must develop grant guidelines for new grant programs, and make them publicly available (including on agency websites) where eligible persons and/or entities are able to apply for a grant under a program.
CGG 3.25: Agencies must ensure that grant guidelines and related operational guidance are in accordance with the CGGs.
CGG 3.22: The Expenditure Review Committee (ERC) will consider guidelines for new grant programs. Where a change is proposed to the guidelines for an existing grant program, agencies should consult with Finance on whether the proposed change will give rise to the need for ERC consideration of the guidelines.

Source: Commonwealth Grant Guidelines—Policies and Principles for Grants Administration, Financial Management Guidance No. 23, July 2009.

2.2 When does the grants policy framework apply?

The term 'grant' has traditionally been used to refer in a general sense to an arrangement where, subject to terms and conditions specified by the grantor, a sum of money is given to an organisation, individual or another level of government for a specified purpose that will also contribute to the achievement of the grantor's policy objectives.

However, the Strategic Review found that a lack of clear principles to guide the classification of transactions and the absence of a common understanding of what exactly constituted a 'grant' or a 'grant program' had resulted in widespread inconsistency and potential for confusion. The Strategic Review reported that there was little clarity as to what key features should distinguish a 'grant' from a 'gift', 'procurement' or other form of financial transaction.[18]

2.2.1 Definition of a grant

Under the principles-based grants administration framework established in response to the recommendations of the Strategic Review, the term 'grant' has been assigned a specific meaning for the purposes of the FMA Regulations and the CGGs. FMA Regulation 3A(1) defines a grant as an arrangement for the provision of financial assistance by the Commonwealth:

1. under which public money is to be paid to a recipient other than the Commonwealth[19]; and
2. which is intended to assist the recipient achieve its goals; and
3. which is intended to promote one or more of the Australian Government's policy objectives; and
4. under which the recipient is required to act in accordance with any terms and conditions specified in the arrangement.

The CGGs, and the provisions of the FMA Regulations that relate specifically to grants administration, only apply to funding arrangements that satisfy the definition of a grant set out in the Regulations. However, a granting activity that will be subject to the CGGs can take a variety of forms, including:

• a payment made on a one-off or ad-hoc basis;
• payments made as a result of competitive assessment; or
• payments made on a non-competitive basis provided specified criteria are satisfied.[20]

In this respect, in the past it has been reasonably common for consideration of grant programs to be focussed on the term 'discretionary grants'. Such schemes are established and implemented by decision of the Australian Government, with the awarding of any grant being at the discretion of the program decision-maker.

However, the new grants policy framework does not make any reference to 'discretionary grants'. This reflects the approach taken in its development, which has been to provide a comprehensive framework for the administration of all financial arrangements that satisfy the definition of a grant under the Regulations. Regardless of the basis on which a program is established or the description assigned to it, the substantive purposes and characteristics of the program will determine whether it is to be taken to be a grant program for the purposes of the FMA Regulations and the CGGs.

Accordingly, in implementing the framework, it is important for agencies to appreciate that a grant program to which the CGGs will apply may arise through a variety of means, including:

• statutory programs under which the basis on which individual grants may be paid is determined by the provisions of
  the legislation;
• programs with a broad statutory basis, but which rely upon executive power for their implementation, including in relation to the selection of funding recipients and the criteria that will applied in that process; or
• executive schemes established and implemented by decision of the Australian Government under authority of the executive powers provided by section 61 of the Constitution and for which specific legislative authority is not sought from the Parliament other than in relation to the appropriation of funding.

Examples of each form of grant program are shown in Figure 4.

Figure 4

Examples of grant programs subject to the CGGs

Example of a grant program established by legislation The Roads to Recovery Program (R2R), under which road funding grants are provided to all local government authorities, was originally established by the Roads to Recovery Act 2000 (R2R Act). That Act established the framework for the program, including the purposes for which the funding could be used. The Act required the gazettal of a list of funding recipients and the amounts each was to receive, which was based upon a formula derived from the process applied in determining grants provided under the Local Government (Financial Assistance) Act 1995. The R2R Act also required the gazettal of the conditions that applied to payments made under the Act. A second R2R program was established under the Auslink (National Land Transport) Act 2005 (now renamed the Nation Building Program (National Land Transport) Act 2009), with a legislative instrument made under that Act specifying the funding recipients and the amount of grant that is to be provided to each recipient. The Minister can vary the list of funding recipients in certain circumstances, but cannot revoke the list once made. By operation of the Act, each amount specified in the legislative instrument is payable to the listed funding recipient. The Act also requires the Minister to make a written determination of the conditions that will apply to all payments, which is required to include certain mandatory conditions stipulated in the Act. As from 1 July 2009, the Roads to Recovery Program has been subject to the CGGs.

Example of a grant program with a broad statutory basis but which relies upon executive power for its implementation Part 6 of the Auslink (National Land Transport) Act 2005 established the AusLink Strategic Regional Program. While the Act specified the types of projects that were eligible for funding and certain mandatory requirements in relation to the making of approval instruments and funding agreements in relation to individual grants, it provided the responsible Minister with considerable discretion as to the matters that would be taken into account in determining whether it was appropriate to approve a particular project for funding and in determining how and when proposals for funding would be invited and from whom. In June 2009, the Act was renamed the Nation Building Program (National Land Transport) Act 2009, with Part 6 of the Act being amended to replace all references to 'Strategic Regional Projects' with 'Nation Building Program Off-Network Projects' and to remove other regional references. However, the provisions of the Act that provide the responsible Minister with discretion as to the matters that will be taken into account in determining whether it is appropriate to approve a particular project for funding as an Off-Network Project and in determining how and when proposals for funding will be invited and from whom continued to operate in the same manner as under the AusLink Act. As from 1 July 2009, the Minister and relevant agency have been subject to the CGGs in exercising that discretion.

Example of an executive scheme established and implemented wholly by decision of government The Regional Food Producers Innovation and Productivity Program is a grant program established by decision of the Australian Government and funded through the annual Budget process. It is directed at improving the productivity, innovation and profitability of Australia's regional food producers. Applicants submit expressions of interest, which are assessed against eligibility criteria. Those considered eligible and likely to meet the program objectives are invited to submit an application. This application is assessed against merit criteria. The Regional Food Producers Innovation and Productivity Program Independent Advisory Panel appointed by the Minister for Agriculture, Fisheries and Forestry assesses all applications against the eligibility and merit criteria set out in the Program Guidelines and make recommendations to the program decision-maker for funding. The Program Guidelines advise applicants that funds are limited and therefore meeting eligibility and merit criteria does not guarantee funding. As from 1 July 2009, the administration of this program has been subject to the CGGs.

Source: ANAO analysis.

2.2.2 Payments that are not subject to the CGGs

FMA Regulation 3A(2) stipulates a number of financial arrangements that are taken not to be grants for the purposes of the Regulations and, therefore, to which the grants policy framework does not apply. However, the general financial management framework does apply to all expenditure of public money, and other policy, process and legal requirements may also apply. For example, a procurement of property or services is identified in Regulation 3A(2) as being taken not to be a grant, but will be subject to the Commonwealth Procurement Guidelines.

Figure 5 sets out the financial arrangements listed at the time of publication of this Guide as not representing a grant for the purposes of the Regulations, and the alternative policy framework that should be complied with in undertaking each type of transaction. Finance Circular No. 2009/03[21] provides further guidance on how to distinguish a grant from other common types of financial arrangements, and the relevant policy and legal framework to apply in administering such payments.

Figure 5

Financial arrangements taken not to be grants and applicable policy framework or guidance

Financial arrangements that are taken not to be grants	Applicable policy framework or guidance within the general financial management framework
The procurement of property or services by an agency, including the procurement of the delivery of a service by a third party on behalf of an agency.	Commonwealth Procurement Guidelines
A gift of public property or public money, including an ex gratia payment.1	Finance Circular 2009/09, Discretionary Compensation and Waiver of Debt Mechanisms
A payment of compensation made under: an act of grace arrangement; or an arrangement for employment compensation; or a similar arrangement.2	Finance Circular 2009/09, Discretionary Compensation and Waiver of Debt Mechanisms, Applicable legislation Legal Service Directions
A payment of benefit to a person, including a payment of an entitlement established by legislation or by a government program.	Applicable legislation, guidelines or program documentation.
A tax concession or offset.	Applicable legislation and Australian Taxation Office rulings
An investment or loan of public money.3	Applicable authorising legislation or s.39 FMA Act. Finance Circular 2005/11, Investment of public money, s.30 FMA Act.
Financial assistance provided to a State in accordance with s.96 of the Constitution.	Applicable legislation Intergovernmental Agreement on Federal Financial Relations National Partnership Agreements Federal Finances Circulars released by the Department of the Treasury on the operation of the Federal Financial Relations Act 2009
A payment to a State or Territory that is made for the purposes of the Federal Financial Relations Act 2009, including the following: General Revenue Assistance; Other General Revenue Assistance; National Specific Purpose Payments; National Partnership Payments.4
A payment that is made for the purposes of the: Local Government (Financial Assistance) Act 1995; Schools Assistance Act 2008; or Higher Education Support Act 2003.5	Applicable legislation
Notes: 1. A gift is an unconditional payment of public money from the Commonwealth to another party which does not require the recipient to undertake the expenditure in accordance with a specified purpose(s). If a financial arrangement takes the form of a conditional gift, it is essentially a grant of money, subject to conditions, and is considered a grant for the purposes of the CGGs. 2. This includes, but is not limited to, payments made under the Scheme for Compensation for Detriment caused by Defective Administration; payments made under section 73 'Payments in special circumstances' of the Public Service Act 1999; payments made under the Remuneration Tribunal Act 1973; and settlements made in accordance with the Legal Services Directions. 3. Some forms of financial assistance provided by way of concessional loans may be subject to the CGGs. 4. Other forms of financial assistance made to States and Territories may be subject to the CGGs. 5. Other forms of financial assistance made to local government or educational institutions may be subject to the CGGs.

Source: ANAO analysis of FMA Regulation 3A(2) as at May 2010 and Finance Circular 2009/03, Grants and other common financial arrangements. 29 June 2009.

2.2.3 Is a grant program needed and appropriate?

Governments have the executive authority to establish and abolish programs, but require the Parliament to appropriate funds to enable expenditure to occur. As providing policy advice to government is a core function of the Australian Public Service, grant programs are often established with the benefit of prior agency advice, but this is not always the case.

In some cases, the development of a grant program may be proposed to government by a relevant agency as a means of addressing particular policy objectives. In those circumstances, it is important to establish that there is a need for the program and that it will be effective in achieving the desired outcomes. This includes:

• clearly identifying and articulating the relevant strategic policy objective;
• undertaking a needs and gap analysis in order to:
  • assess the availability of funding from other existing sources that could be accessed by intended funding recipients to achieve the same or similar objective;
  • identify the level of unmet demand within the community for funding assistance within the area under consideration; and
  • assess whether an existing grant program could be expanded or modified to meet the identified need, rather than establishing an additional program; and
• consideration of alternative financial arrangements in order to assess whether a grant program is the most appropriate approach to achieving the relevant government outcome.

Where a grant program is selected, it is also worth evaluating the impact of the program for possible unintended consequences, whether economic, environmental, social or political. For example:

• a grant program aimed at a particular line of medical research may appear to give government endorsement to ethical or moral positions, which may be opposed by particular sectors of the community; or
• the design of a grant program directed at promoting activity within a particular industry needs to include consideration of the potential for the program to cause the industry to grow at an unsustainable pace and/or to give rise to regulatory risks.

In other cases, the Government may determine that a grant program is to be established in order to achieve a particular policy objective, with the relevant agency being responsible for implementing that decision. In those circumstances, it is advisable that agencies consider, as part of the implementation process, whether further needs analysis would assist in ensuring the available funding will be directed towards funding recipients or projects that will maximise the effectiveness of, and value for money achieved by, the program. Again, it would also be appropriate for agencies to provide advice to government in relation to the risk of unintended consequences arising, and the manner in which those risks might be best mitigated. Analysis of that nature will inform the detail of the program's implementation.

2.2.4 Consideration of alternative financial arrangements

Grants are one type of financial arrangement available to achieve a particular strategic objective. However, a range of other financial arrangements is also potentially available to achieve the same objective, including those identified in the FMA Regulations as not being 'grants' for the purposes of the Regulations and the CGGs (see Figure 5).

In that context, it would not be appropriate for an agency to elect to structure a particular program or payment as a procurement or other type of financial arrangement, rather than as a grant, for the principal purpose of avoiding the application of the mandatory requirements now applying to the administration of grants.[22] In this respect, Finance has advised that, in considering possible alternative approaches, agencies should focus on the substantive purposes and characteristics of the financial arrangement, seek advice on their implications, and document the reasons for adopting them.[23]

Similarly, in some cases government may provide discretionary assistance by way of mechanisms such as discretionary compensation payments, act of grace payments, ex gratia payments or by waiving debts owed. In general, this assistance may be granted where it is considered that the Australian Government has a moral responsibility to provide assistance, rather than a legal responsibility. The making of unconditional gifts, or ex gratia payments, may avoid the administrative costs involved in oversighting the satisfaction of the terms and conditions associated with a grant.[24] However, the ex gratia payments policy managed by the Department of the Prime Minister and Cabinet provides that the provision of an ex gratia payment is only considered appropriate once all other avenues have been exhausted.[25]

Consideration of the alternatives may reveal less costly or more effective means of achieving a policy objective than through a grant program. In considering the relative merits of alternative funding arrangements, it is important that agencies recognise that the nature of the financial arrangement that is adopted will give rise to particular legal and/or policy requirements which must be observed in implementing each form of arrangement. For example:

• loans, or a mixture of loans and grants, perhaps on favourable terms, may be a better economic option, particularly for larger amounts or where commercial activities are being assisted. Although funding organisations may be reluctant to assume the extra administrative burden of a loan program, the cost of such work may well be offset by a reduction in the net cost of the assistance. The opportunity costs incurred in making grants or loans should also be clearly identified during the planning process[26]; or
• relief from fees or taxation may be another form of assistance that may give better value for money. Care must be taken in these circumstances to ensure that all implications of the arrangement are fully costed from a whole-of-government perspective, and that the policy ramifications are thoroughly examined with the ATO or fee-charging authority.[27] There are also reporting requirements associated with such arrangements, particularly through the Tax Expenditure Statement required by the Charter of Budget Honesty Act 1997.

It is important to examine both the economic and policy consequences of the various options and ensure that these are consistent with the Government's objectives and policies, and obligations arising from international agreements (such as trade agreements, environmental protocols or health conventions).

Programs may be a hybrid of financial arrangements

In some cases, it is possible that a single program may include payments that are subject to the CGGs, as well as payments that the FMA Regulations specify are taken not to be grants and to which the CGGs, therefore, do not apply.

For example, as discussed, one option for the design of a program may involve the use of a mixture of loans and grants. Under the terms of the FMA Regulations, such a program may involve some payments (grants) which are subject to the grants policy framework, together with other payments (loans on favourable terms) which may or may not be subject to that framework (depending upon the terms of the loan), but which are subject to the general requirements of the financial framework and other relevant legislative and policy requirements.

In other cases, a single grant program may involve payments that, while similar in most substantive aspects, differ as to whether they are subject to the CGGs based on the identity of the funding recipient and the administrative arrangements under which the various payments are made.

In these circumstances, it will be important that agencies accurately identify the obligations attached to the administration of each payment and design the program's administrative arrangements accordingly. However, it is also appropriate for consideration to be given in the program planning phase to the desirability in terms of accountability, transparency and cost-effective administration of having such an arrangement, or before amendments are made to an existing program that will result in such an arrangement.

Application of the principles underpinning the CGGs to payments that exhibit similar characteristics as 'grants' (as defined in the FMA Regulations)

A further consideration is that some payments defined as not being a grant for the purposes of the Regulations may, nevertheless, exhibit many of the same characteristics as grant payments to which the CGGs apply. In that context, whilst not mandatory, consideration of the principles outlined in the CGGs may assist to promote transparency and accountability in the effective administration of such payments.

 

 

 

 

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