Rules on Conflict of Interest

Conflict of Interest Rules of the Foundation for Baltic and East European Studies

Adopted by the Foundation’s Board on 30 September 2024

Conflict of interest (CoI) concerns doubt about impartiality. Rules on CoI serve to ensure objectivity and impartiality in case management. Another purpose of these rules is to generate trust in those affected by such cases and among the public.

Legislation

The Foundation for Baltic and East European Studies(Östersjöstiftelsen)is not subject to the Swedish Administrative Procedure Act (SFS 1986:223), which contains CoI provisions for central government agencies. However, the Foundation’s activities show marked public-sector features. Accordingly, on its own initiative, the Foundation has opted to apply the above-mentioned Act’s CoI provisions, adapted for its own purposes and to its own work.

Who is covered

The Foundation’s CoI rules apply to members of its Board, research committee and investment committee; employees; and external experts and consultants engaged by the Foundation.

Conflicts of interest

For anyone tasked with managing or deciding on a case, there is a conflict of interest if the matter concerns the individual personally or anyone in his or her immediate family (spouse, cohabitant, parent, child or sibling), or a legal entity in which the person or close family members own a significant interest or which they represent. Similarly, a CoI exists if the conclusion of the case may be expected to cause a significant degree of benefit or harm to the person or such family member or legal entity. Moreover, a person is involved in a CoI in the event of any particular circumstance liable impair trust in the person’s objectivity or impartiality in the case.

Members of the Foundation’s Board, research committee and investment committee, and employees may not apply to the Foundation for funding in the course of, respectively, their Board terms, committee membership or employment in the Foundation.

The Foundation’s guidelines for personal trading in financial instruments regulates how Board members, members of the research and investment committees, and employees should conduct any trading of their own in financial instruments in accordance with current legislation, the Foundation’s interests and best ethical practice. Circumstances that may be assumed to constitute conflicts of interest in such trading must be managed according to these CoI rules.

Reporting a conflict of interest

Those who are aware of a circumstance that may be assumed to involve CoI for their own part must disclose it of their own accord. Anyone who is aware of a circumstance that may be assumed to constitute a CoI for a person involved in management of the case in question must disclose it, if the person concerned has not taken note of the circumstance. Employees must inform their immediate superior. Board members must inform the Board Chair, who in turn is obliged to inform the Deputy Chair or the whole Board. Members of the Foundation’s research and investment committees must inform the chairs of their respective committees, who must then inform the Board Chair of any circumstance that may be assumed to implicate the member in a CoI. This transparency safeguards objectivity and impartiality in case management, as well as outsiders’ trust in the Foundation’s adherence to these principles.

When the Foundation makes inquiries about expert and consulting assignments, it must question prospective external experts and consultants in writing about CoI. If a conflict may be assumed to exist, the person or organisation concerned may not receive any assignment. People engaged for assignments must be duty-bound to report to the Foundation, without delay, any CoI situations that arise.

Documentation of CoI assessments

Investigation of whether a conflict of interest exists must always be included on the agenda for Board meetings and also the agendas of the committees that work on the Board’s behalf. Whether a CoI exists must be settled by the Board or respective committee in every specific case. A CoI must be noted in the minutes of meetings, and cases in which the question of CoI has been investigated but no CoI has been found to exist must also be recorded in the minutes. Regarding other cases of CoI that have been reported and deemed to exist, these must be noted in a document filed with the case in question.

CoI management

A person involved in a conflict of interest may not manage the case. Accordingly, (s)he must not take any preparatory action or participate in settling the case. The person implicated in a CoI must leave the room when the matter is addressed, discussed and decided upon, and may not otherwise, in any way, take part in dealing with the case. However, a person who has reported a CoI may be asked about factual circumstances relating to the application or case concerned, if decision makers deem this essential to obtain sufficient information on the matter and the information is obtainable from no one else. This must (just as when CoI is reported) be entered in the minutes of the meeting, or otherwise documented in writing in conjunction with the case management.

Should the person chairing a meeting be involved in a CoI, a special meeting chair must be appointed for the case in question. If the Foundation’s research committee or investment committee does not constitute a quorum as a result of a CoI involving a committee member, the Foundation’s Board must decide on the case.