1. INTRODUCTION & APPLICABILITY
TTTI’s efforts to raise the ethical standards of government officials, business people and other individuals could be compromised by any ethical lapses on the part of individuals representing TTTI. It is essential that everyone associated with TTTI be highly sensitive to potential conflicts of interest.
For the purpose of this policy, a conflict of interest is a situation where anybody associated with TTTI is confronted with choosing between the duties and demands of their position and their own private interests. As such, this policy applies, except as otherwise stated, to every person associated with TTTI, as a board member, officer, resource person or staff member. The “interests of any person associated with TTTI” include the interests of any person with whom they have a close personal relationship, including their spouse, life partner, children, parents or siblings.
Conflicts of interest may arise from time to time in the course of such persons’ activities and decisions. They may arise in their work for TTTI with regard to pecuniary or financial interests, or interests that impede them in their duty to act in the best interests of the TTTI.
2. GENERAL POLICY
- Every person associated with TTTI (according to paragraph 1) must avoid or manage any potential real or perceived conflict of interest (inter alia by refraining from any decision making or voting on matters subject to a potential conflict of interest), and openly acknowledge any potential or actual conflict of interest which arises through his/her association with TTTI.
- Members of the Board of Directors shall declare all their financial and non-financial interests apart from those which could not potentially lead to or could not conceivably be perceived as a conflict of interest. Such declaration shall be made by way of an online register, which shall be open to the public. Where there are personal safety or similar serious concerns about full publicity, parts or even the whole of the declaration should be submitted to the Chair of the Ethics Committee who shall hold it, and act upon it as appropriate, in confidence, while TTTI should then demonstrate that due processes are in place for robust conflict of interests management.
3. REMUNERATED WORK CONTRACTS AND CONSULTANCIES
- Staff members (including management) of TTTI sometimes are employed by, or undertake paid work for, other organisations. Such work may be undertaken:
- where the work is related to corruption, only with the express permission of their superior;
- in all other cases, only if the work is declared as early as practicable.
- Much of TTTI’s work is done by individuals who are not employees of TTTI but who act for or on behalf of TTTI on a voluntary basis. This includes, among others, the members of the Board of Directors, the resource persons and enlisted volunteers active in TTTI. Many of such individuals will have business, professional and other affiliations.
- Members of the Board of Directors, or companies or other organisations with which such Members are currently affiliated, may not perform remunerated work for TTTI. Similarly, members of the Board of Directors or companies or other organizations with which such individuals are currently affiliated, may not perform remunerated work for TTTI.
- Members of the Board of Directors, or companies or other organizations with which such members are currently affiliated, may apply and compete for remunerated work contracts with TTTI or companies or other organizations with which such individuals are currently affiliated, may apply and compete for remunerated work contracts with any of the other National Chapters or with the TI Secretariat; provided however that they are not offered any advantages over any competitors with respect to being awarded or carrying out such work. They must not utilize privileged information and do everything to contradict the perception of having utilized privileged information; in addition, they will not exercise their Board function to the extent it relates to the conditions of the contract or the selection or supervision of such contract. In other words, they do not need to be disqualified in such cases because of their affiliation with TTTI, but neither may they be given the “inside track”. When doing non-TTTI related work, Board members or their companies shall not utilize privileged TTTI information, and shall also be sensitive to the perception that they might be utilizing such information.
- Resource persons and volunteers active anywhere in TTTI, or companies or other organizations with which such individuals are affiliated, may apply and compete for remunerated work contracts with TTTI, provided they are not offered any advantages over any competitors with respect to being awarded or carrying out such work. They must not utilize privileged information and do everything to contradict the perception of having utilized privileged information. In other words, they do not need to be disqualified because of their affiliation with TTTI, but neither may they be given the “inside track”. When doing non-TTTI related work, resource persons shall not utilize privileged TTTI information, and shall also be sensitive to the perception that they might be utilizing such information.
- TTTI will be transparent in its decision-making processes when commissioning paid work, and will follow transparent tender procedures.
- TTTI will not hire or undertake any business relation with members of immediate family, i.e., a spouse, parent, child, or sibling of any of its staff or of its Board members without specific authorization through unanimous decision of the Board which may consider such possibility only after the due process ensuring open competition and level playing field has been exhausted.
4. GIFTS AND ENTERTAINMENT
No person associated with TTTI or any of its National Chapters shall accept any gift, entertainment, loan or anything else of value from any organisation or individual if it could be reasonably construed or perceived that the gift is motivated by a wish to influence TTTI.
5. HOW TO DEAL WITH A POSSIBLE CONFLICT OF INTEREST
- Potential conflicts of interest should be identified and declared by the person in potential conflict, or reported by other members of the movement, as soon as they become aware of such potential conflict of interest.
- Such disclosure or report should be made to the Chair of TTTI or to another suitable senior officer or director.
- The evaluation of a potential conflict of interest must be made by TTTI Board of Directors such as the Board’s Ethics Committee. The evaluation may determine the absence of a conflict of interest, or it may lead to the conclusion that (i) the respective person should not go ahead with the evaluated activity or that (ii) he/she should recuse him/herself from participating in decision making by TTTI with reference to the matter in conflict.
- The Chair of TTTI is responsible for ensuring that all persons associated with the activities of TTTI are made aware of the policy and procedures regarding conflict of interest. In addition, these policy and procedures should be made available to the general membership through publication, for example, on the website or in a newsletter.
6. DISCLOSURE OF PAYMENTS TO TTTI
When TTTI makes payments including allowances – but excluding approved expenses and per diems – to a member of the Board or a staff member – this should be declared in full in the annual Financial Statement and Annual Report of the TTTI. Such reporting should also outline the procurement/tender procedures conducted that led to such payment.
7. TTTI BOARD’S ETHICS COMMITTEE
TTTI’s Board of Directors has established an Ethics Committee for the purpose of providing advice on ethical questions to anybody associated with the movement. The Terms of Reference and contact details of the Board’s Ethics Committee can be obtained on TTTI’s website.
8. SCOPE OF THIS POLICY
This policy sets minimum standards.