Basis: Decree-Law No. 2011-88 (non-profit purpose, transparent management, prohibition of distributing profits to members); Penal Code provisions on abuse of office and unlawful benefit; Organic Law No. 2017-10; donor and good-governance standards.
1. Who and what
It applies to Board members, officers, staff, experts, interns, volunteers, consultants and members of committees. A conflict of interest exists when a person’s financial, family, professional, political or personal interest, or a duty to another organisation, could improperly influence — or reasonably appear to influence — their judgement or duties at TIPCS. A perceived conflict is treated like an actual one. Close family means spouse, partner, parents, children, siblings and anyone sharing the household.
2. Typical situations
- Hiring, paying or contracting a relative or a business in which you or a relative has a stake.
- Taking part in selecting a grantee, partner, supplier or applicant to which you are tied.
- Holding a paid role, board seat or advisory post with a donor, competitor or partner of TIPCS.
- Using TIPCS information, name, premises or contacts for private gain or for a political party or campaign.
- Accepting gifts or favours from someone who seeks a decision from TIPCS (see the Anti-fraud policy).
- Research conflicts: funding or personal ties that could affect findings. These must be disclosed in the publication.
3. Declare, step aside, record
- Every Board member, officer and employee signs a declaration of interests when joining and renews it each January; consultants and experts declare before each assignment.
- A new conflict is declared in writing as soon as it is known, and always before the discussion of the matter.
- The person concerned leaves the discussion and does not vote or influence the decision; the minutes record the declaration and the withdrawal.
- The Chair of the Board decides how to manage a conflict (for a conflict of the Chair, the Vice-Chair); options are recusal, independent review, or declining the transaction. The register of interests is kept by the Secretary General and reviewed by the Board each year.
4. Related-party transactions
Any payment or contract with a Board member, a staff member’s relative or an entity they control needs prior written approval by the Board without the interested person, a documented comparison with market terms, and disclosure in the annual accounts. Board members are not paid for serving on the Board.
5. Independence of research and politics
TIPCS is nonpartisan. Personnel may hold personal political views but may not use TIPCS’s name or resources for party or electoral activity, and must say when they speak in a personal capacity. A funder may not decide findings or block publication.
6. Breaches
Failure to declare a conflict, or acting in it, is misconduct and can lead to cancellation of the decision, removal from the role, termination, recovery of any benefit and referral to the authorities. Concerns about a possible conflict can be raised under the Whistleblowing and complaints policy.
To raise a concern, write to Contact@tipcs.org with the subject “CONFIDENTIAL – Concern”.
