COUNTRY COORDINATING MECHANISM

SIERRA LEONE CONFLICT OF INTEREST POLICY

Background: The Country Coordinating Mechanism Sierra Leone (CCMSL) is composed of not more than 25 members with proportional representation from Academic/Educational Sector, Government, NGOs/CBO’s, PLWDs, Private Sector, Inter-Religious/Faith Based Organizations, and Multi/Bilateral Development Partners.

FUNCTIONS OF THE CCMSL

• CCM mobilizes resources at the country level by organizing and submitting proposals to the Global Fund.
• Selects Principal Recipients(PRs) of the Grants
• National AIDS Secretariat: PR for HIV/AIDS Round 9
• Ministry of Health and Sanitation: PR for Malaria Round 10 and TB Round 7
• Catholic Relief Service (CRS): PR for Malaria Round 10
• Provides oversight to grant implementation to ensure successful outcomes.
• Provides Governance during  grant implementation

To fulfil these roles, a Conflict of Interest Policy is signed by all CCM Members in order to achieve a dynamic and genuine multi-stakeholder partnership with Government, civil society, other partners and beneficiaries.

Conflict of Interest Policy for CCM Sierra Leone Members 2011 to 2012

Recognizing the need to be fair, equitable and transparent in managing conflicts of interest that may arise in the course of the performance of its oversight function, and in keeping with international best practices in corporate governance, the Country Coordinating mechanism (CCM) Sierra Leone has adopted the following Conflict of Interest Policy as contained in the CCMSL Bylaws:

1.         The concept of conflict of interest recognizes that the judgment of even the most well-meaning persons may be impaired when their own interests or those of close associates, including closely-associated organizations, are affected

2.         Areas of conflict include:

Members advocating for approval of a proposal or grant in which his or her government, entity, or organization will serve as principal recipient, implementing agency, or play some other direct project implementation role or realize some other direct financial benefit;

CCM Member advocating for endorsement of a certain decision from which his or her government, entity, or organization will realize some direct financial benefit;

CCM Members using their positions to advocate for selection of a service contract between the CCM and or Principal Recipient and an Associated Institution

3.         Types of interest to be addressed include:

3.1       Financial interests: A pecuniary interest refers to a direct, indirect or deemed financial interest that a CCM member holds in relation to decisions or actions taken at a CCM meeting. A pecuniary interest is a financial interest, although it does not have to be a cash interest. It can mean monetary benefits that will be received or could be received, either in cash or as an increase in asset value and extends to the disbursement of, access to, or use of any funds, either directly or indirectly, related to CCM action from  Global Fund resources.

3.2       Programmatic Interests: A programmatic interest refers to direct benefits to a special programme or department in a public sector, civil society or private sector organization in promoting a proposal or a level of funding for a proposal, or recommendations regarding the utilization of awards, or the monitoring of project performance that disregard the goals of the funding sources or the overall national interests.

3.3       Administrative Interests: An administrative interest refers to any directives or considerations concerning specific policies originating in the CCM that will influence decisions on approval of proposals, level of funding, utilization of awards, or monitoring of performance.

4.         All CCM members must declare any interest that may or will arise in the course of undertaking their duties on behalf of the CCM whenever the CCM considers a new Proposal or new source of funding. The magnitude or extent of the interest is irrelevant to the determination as to whether the interest exists.

5.         As long as the member declares his/her interest in a particular issue or organization to the CCM in advance of agenda discussions, there is no conflict of interest. All disclosures of interest must be explicitly noted in the Minutes of CCM meetings. Failure of a CCM member to disclose an interest constitutes a conflict and a breach of duty.

6.         The following protocol applies to members declaring interests:

6.1       Disclosure of the interest is made as soon as possible after the commencement of the meeting;

6.2       The member withdraws from his/her place, leaving the room in which the meeting is held for the duration of the consideration of the matter;

6.3       The member refrains from taking any part in the discussion of the matter and from voting on any question relating to the matter;

6.4       The member refrains from attempting in any way, whether before, during or after the meeting, to influence the decision of the CCM with respect to the matter.

6.5       The Constituency “Alternate" member takes the place of the substantive representative, the latter having been disqualified from taking part in any further deliberations of the matter in which he/she has a conflict of interest.

7.         If a suspected conflict of interest is reported by any party, the Chair of the CCM will review the matter immediately to determine whether the CCM member in question has failed to declare an interest, and is therefore in breach of his/her responsibility.  If the matter is deemed ‘substantive’, the Constituency will be immediately requested to withdraw the affected member from the CCM.

8.         If a CCM member has failed to disclose an interest and a financial benefit has occurred    either directly or indirectly, the CCM will take all reasonable measures to revoke any benefit.

In addition, the CCM member and his/her associates or associated organization(s) involved, shall be reported to the relevant Constituency they represent for further investigation and disciplinary action.

9.         A conflict of interest clause will be incorporated in all contracts and agreements governing expenditure of Global Fund monies in Sierra Leone. Any conflicts that cannot be satisfactorily resolved will lead to the suspension of the relevant contract or agreement.

CONFLICT OF INTEREST DECLARATION

I, _________________________________________ (name), agree by my signature below that, if appointed, I pledge to comply with the following ethics guidelines for the Country Coordinating Mechanism of Sierra Leone, Global Fund for HIV/AIDS, TB and Malaria Program.

As a CCM member, I shall not discuss, advocate, or vote on any matter in which I have a conflict or potential conflict of interest or an interest which reasonably might appear to be in conflict with the concept of fairness in dealing with Sierra Leone Global Fund business.

A conflict of interest or a potential conflict occurs if I have a separate, private, or monetary interest, either direct or indirect, in any issue or transaction under consideration.

I will state my position to the other members of the CCM on a conflict or potential conflict of interest on a particular issue during a meeting. I will state the nature of the conflict, acknowledging that I have a separate, private, or monetary interest, either direct or indirect, in the issue or transaction under consideration. I will then excuse myself from considering and voting on the matter. In cases where I declare a conflict or potential conflict of interest, I shall excuse myself from the CCM meeting until all discussion, consideration, and voting is completed on the matter in question.

In violation of this provision, I will be subject to removal from the CCM and may face further disciplinary action.

If I have any questions or need assistance regarding the interpretation of these ethics guidelines or other conflict of interest matters, I will contact either the Chair or Secretariat of the CCM who will assist me with questions and interpretations and will provide a recommendation on whether or not I should excuse myself from voting.

I may request a response in writing.

CCM Member Name________________________________________

Signature and Date _______________________________________________

Witness Signature and Date__________________________________________

Contact CCMSL:

45 Adelaide Street Freetown Sierra Leone West Africa.

Mobile # +232/76/33 623030

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