Bylaw 8. Ethics & Conflicts (Implementation Rules)

Last modified: September 5, 2025
For versions:
Estimated reading time: 5 min

(Swiss Verein; Zug register; principal base Geneva. Implements Article 16 (Ethics, Conflicts & Related-Party Transactions) with operational rules on declarations, recusals/paper walls, and gifts & hospitality. Preserves Independence & Non-Affiliation (Art. 3); embeds CB (Privy Council) clearance, Council Register/Gazette (Arts. 9.3, 12–13); aligns with Swiss anti-corruption norms and international ABAC standards. Cross-refs: Arts. 1–5, 6–9, 10–11, 12–15, 17–21; Bylaws 1 (Committees), 4 (Meetings & Records), 5 (Membership/GA), 6 (Programs/KPIs), 7 (Procurement/Vendors/Grants). Annexes: N (Conflicts & RPT Policy), J (Independence Impact Assessment), W (Records), X (Gazette), AB (Open-Contracting), L (Identity/InfoSec). EN controls; FR/DE companions may be issued.)


8.0 Scope, Persons Covered & Core Duties

(a) Persons covered. Trustees; Committee members; Chairs (Regional/Thematic); Executive Management (EM); CB personnel/consultants; Program Directors; staff with procurement, finance, data, privacy, or model-governance duties; election officials; any secondee/contractor with comparable functions.
(b) Core duties. (i) Declare interests truthfully and promptly; (ii) Recuse when independence/objectivity could be impaired; (iii) Comply with ABAC and sanctions/KYC; (iv) Record interactions (gifts/hospitality); (v) Cooperate with CB reviews; (vi) Protect confidential/personal data (Arts. 13 & 15).
(c) Non-retaliation. Whistleblowing is protected (Art. 16.4). Retaliation is a disciplinary offense.


8.1 Annual Declarations & Event-Based Updates

8.1.1 What must be declared (minimum)

  1. Financial interests (direct/beneficial) in entities that: supply GRF; receive funds from GRF; co-publish with GRF; or could be materially impacted by GRF decisions.
  2. Outside positions (director, officer, advisor, trustee, partner) and paid services (consulting/mandates) in the last 24 months.
  3. Close relationships (spouse/partner, household member, dependent, first-degree relative) employed by, or holding material interests in, relevant entities.
  4. Gifts/hospitality exceeding de minimis (see §8.3) received in the past 12 months from any interested party.
  5. Funding ties (scholarships, grants, sponsorships) personal or institutional that could affect independence.
  6. Political/lobbying roles that might be perceived as influencing GRF work (personal political activity is allowed but must be separate from GRF and disclosed if relevant).
  7. Ongoing disputes/litigation or debarments related to integrity, sanctions/export controls, or data/security.

8.1.2 When & how to declare

(a) Annual declaration: filed via CSR each January (or upon onboarding) using CB-approved form; QES/AES signature required.
(b) Event-based update: within 10 calendar days of any change (new role, contract, gift over threshold, family employment, funding award, procurement stage entry, etc.).
(c) Pre-meeting confirmation: agenda-specific conflicts reaffirmed at the start of each meeting and minute’d (Bylaw 4).
(d) Accuracy & completeness: omissions are treated as misrepresentation. CB may request evidence (employment letters, cap tables, grant letters).

8.1.3 CB review & registers

(a) CB logs declarations in the Conflicts & RPT Register (Annex N), classifies risk level (Low/Moderate/Material), and issues one of: No Action, Manage with Conditions (recusal/wall), or Not Permitted.
(b) Where donor/vendor capture risk exists, CB conducts an Independence Impact Assessment (IIA) (Annex J).
(c) Material declarations are summarized in the Council Gazette (lawful redactions).

8.1.4 Sanctions/KYC/AML screening

CB screens covered persons proportionately against SECO/EU/OFAC and adverse media at onboarding and annually; any hit triggers conditions or ineligibility (Art. 8.4(d)).


8.2 Recusal Mechanics & Paper Walls

8.2.1 Triggers for recusal (illustrative, non-exhaustive)

  1. You (or a close relation) hold a material interest (≥1% equity or >CHF 10k exposure) in a party to the matter.
  2. You serve as director/officer/advisor to a party or competitor.
  3. You’ve received gifts/hospitality from a party exceeding annual caps (§8.3).
  4. You have pending employment/mandate discussions with a party.
  5. You have prior involvement (e.g., authored a competing bid/analysis) that prevents objective judgment.
  6. An IIA finds capture risk.

8.2.2 Recusal process (meeting & non-meeting contexts)

(a) At meetings.

  • Declare the conflict before the item.
  • The Chair decides (on CB advice) the scope: discussion-only exclusion or full recusal (no presence).
  • The minute must record: nature of interest, decision, whether quorum/vote recalculated, and Clearance/CRE IDs if relevant.
    (b) Between meetings (procurement/program flows).
  • Notify owner + CB in writing.
  • Reassign the task or escalate to an alternate.
  • CB updates CSR permissions and marks item walled.

8.2.3 Effect of recusal

(a) No access to papers/data rooms for that item; no attendance at related sessions; not counted toward quorum or vote on that item.
(b) No informal influence: no behind-the-scenes canvassing; no review of drafts.
(c) Cooling-off: for procurement/awards, recusals persist until contract signature + 6 months, or longer if CB so orders.

8.2.4 Paper walls (digital & physical)

(a) Digital controls. CSR permissioning removes walled persons from folders/threads; emails re-routed; audit trail retained.
(b) Physical controls. Red-stickered packs; separate rooms or excusals; sealed ballot custody (Bylaw 4).
(c) Data walls for analytics. Separate compute/workspaces; blinded datasets if participation is necessary for QA but poses bias risk (CB-approved protocol).

8.2.5 Leadership substitutions & continuity

When a Chair/Trustee is recused, the Vice-Chair/alternate handles the item. The substitution is minute’d and signatory powers applied per Annex G.

8.2.6 Reviews, appeals & misuse

(a) A recused person may request reconsideration by submitting new facts; Chair + CB decide within 5 Business Days.
(b) Failure to recuse or breaching a wall is misconduct and may trigger suspension/removal (Art. 8.5) and contract remedies (if vendor-side). CB logs violations in the Register.


8.3 Gifts & Hospitality — Limits, Logs & Controls

8.3.1 Principles

Zero-cash, zero-quid-pro-quo, transparency by default. No gift or hospitality may be accepted or offered if it could reasonably be seen as influencing a GRF decision or creating an expectation of favorable treatment.

8.3.2 Definitions

Gift: anything of value not paid at market rate (including discounts not generally available, services in kind, travel upgrades, gift cards, tickets).
Hospitality: meals, receptions, local transport, or event attendance with a legitimate business purpose.
Interested party: any vendor, bidder, grantee, sponsor, donor, sovereign delegation, or other counterparty with business before GRF or likely to have within 12 months.

8.3.3 Acceptance thresholds (receiving from an interested party)

  • Per-item de minimis:CHF 100.
  • Aggregate per source per calendar year:CHF 300.
  • Event tickets (face value): ≤ CHF 200 only if hosted and with a direct business purpose; otherwise decline or pay face value personally/through GRF if justified.
  • Meals/hospitality: reasonable and incidental to business (≤ CHF 100 per person per event).
  • Sponsored travel/lodging: prohibited unless pre-approved by CB with IIA and recorded as Sponsored Participation (Bylaw 5.11). GRF-funded travel uses published per-diems (Bylaw 7).

Absolute prohibitions: cash or cash-equivalents (gift cards, crypto); loans; personal discounts; services for family members; gifts during active RFP/standstill periods; any secret or non-logged gift.

8.3.4 Offering gifts/hospitality (by GRF to others)

Permissible modest hospitality in line with local norms and per-diems; no lavish or frequent entertainment; no inducements tied to decisions. All hosting over CHF 100 per person per event requires line-manager approval; over CHF 200 requires CB notice.

8.3.5 Logging & approvals

(a) All accepted/offered gifts or hospitality ≥ CHF 50 are logged in the Gift & Hospitality Register within 10 calendar days (counterparty, nature, value, purpose, approval).
(b) Items over thresholds require pre-approval by the relevant Committee Chair (Trustees) or ED/CB (staff/Chairs).
(c) Cultural protocol gifts over thresholds are either returned, paid for, or donated to GRF (with receipt) and recorded.

8.3.6 Special contexts

(a) Conferences & speaking fees. Honoraria are declined or paid to GRF unless CB approves personal acceptance with IIA. Travel costs follow §8.3.3.
(b) Sovereign/delegation gifts. Treat under these thresholds unless applicable law requires otherwise; CB documents any variance.
(c) Vendors/grantees during sourcing. No gifts/hospitality from issue of RFP to end of standstill (Bylaw 7.5).

8.3.7 Monitoring, publication & enforcement

(a) CB reviews the Register quarterly; red-flag patterns escalate to ECC/ARC.
(b) An annual summary (aggregated, lawfully redacted) is published in the Council Gazette.
(c) Breaches trigger proportionate remedies: return or reimbursement, written warning, clawback, suspension/removal (Art. 8.5), supplier debarment (Bylaw 7.9), and—where applicable—referral to authorities.


8.4 Related-Party Transactions (RPT) — Interface (summary)

All RPTs follow Annex N: prior disclosure; independent valuation (if material); CB Pre-Clearance; non-participation by the interested person; Board or Committee approval thresholds per Art. 9; CSR entry and Gazette summary.


8.5 Training, Certifications & Records

(a) Annual training for covered persons: ABAC, conflicts/IIA, elections code, procurement walls, data/privacy, sanctions/KYC, gifts/hospitality rules.
(b) Annual certification (QES/AES) of compliance and completeness of declarations; non-certification places the individual on administrative hold.
(c) Record retention: declarations, walls, approvals, and the Gift/Hospitality Register are retained ≥10 years (Annex W). Legal Holds (Art. 13.4) override destruction.


8.6 Enforcement & Remedies

(a) Low/Moderate severity: counseling, written warning, mandatory training, restitution/return of gifts.
(b) Material severity: removal from panels/roles, suspension or removal from office (Art. 8.5), clawback, supplier debarment, grant termination.
(c) Referral: suspected bribery, fraud, sanctions/export-control breaches are referred to competent authorities (Swiss or foreign) on GC/CB advice.
(d) Transparency: material outcomes are logged in CSR and summarized in the Gazette with lawful redactions.


8.7 Quick-Reference (Thresholds & Timelines)

Item Standard
Annual declaration filing Each January (or at onboarding)
Event-based update ≤ 10 calendar days
Gift per item (accept) ≤ CHF 100
Gift per source per year (aggregate) ≤ CHF 300
Event ticket (hosted, business purpose) ≤ CHF 200
Meals/hospitality per person per event ≤ CHF 100
Log any gift/hospitality ≥ CHF 50 (within 10 days)
Sponsored travel/lodging Prohibited unless CB-approved IIA & register entry
RFP/standstill window No gifts/hospitality from vendors/bidders

Design result: A Swiss-grade, trust-minimized ethics regime: full-spectrum declarations, swift event-based updates, hardwired recusals and paper walls, and bright-line gift rules—all logged, permissioned, and gazetted—so GRF’s decisions stay demonstrably independent, lawful, and auditable at multilateral scale.

Was this article helpful?
Dislike 0 0 of 0 found this article helpful.
Views: 27

Continue reading

Previous: Bylaw 7. Procurement, Vendors & Grants
Next: Bylaw 9. Data Governance & Model Risk

Leave a Reply

Your email address will not be published. Required fields are marked *

Have questions?