(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)
- 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.
- Outside positions (director, officer, advisor, trustee, partner) and paid services (consulting/mandates) in the last 24 months.
- Close relationships (spouse/partner, household member, dependent, first-degree relative) employed by, or holding material interests in, relevant entities.
- Gifts/hospitality exceeding de minimis (see §8.3) received in the past 12 months from any interested party.
- Funding ties (scholarships, grants, sponsorships) personal or institutional that could affect independence.
- 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).
- 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)
- You (or a close relation) hold a material interest (≥1% equity or >CHF 10k exposure) in a party to the matter.
- You serve as director/officer/advisor to a party or competitor.
- You’ve received gifts/hospitality from a party exceeding annual caps (§8.3).
- You have pending employment/mandate discussions with a party.
- You have prior involvement (e.g., authored a competing bid/analysis) that prevents objective judgment.
- 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.