POLICY REGARDING CONFLICTS OF INTEREST

DECISIONS ON BICKERING RULES IN THE SWEDEN-ESTONIA COOPERATION FUND

A conflict of interest (COI) is a situation that gives reason to doubt a person's impartiality. A COI policy is intended to guarantee objectivity and impartiality in selection, presentation and decision procedures and to instill confidence in all parties regarding such objectivity.

The COI policy is aimed at "persons charged with handling a matter". Such persons include those in charge of selection and presentation as well as those who make decisions, whether they are members of a board administrators or officials, in other words anyone who can influence the outcome of a matter.

Conflicts of interest involving private interests, personal involvement or family ties disqualify the person charged with handling a matter:

• if the matter concerns the person him- or herself or his/hers spouse, parent, child, sibling or other closely related person .

• if the person or someone closely related to him/her can expect extraordinary advantage or detriment from the outcome of the matter. Conflicts of interest involving legal representation disqualify the person charged with handling a matter.

• if the person or someone closely related to him/her is the legal representative of someone that the matter concerns.

• if the person or someone closely related to him/her is the legal representative of someone who can expect extraordinary advantage or detriment from the outcome of the matter.

Conflicts of interest involving proxies or agents disqualify the person charged with handling a matter:

• if the person has served someone as a proxy or has assisted that person for payment as regards the material issue.

Conflicts of interest involving sensitive situations disqualify the person charged with handling a matter:

• if there is some other special circumstance that is likely to undermine confidence in his/her impartiality in the matter that is not covered by the aforementioned COI categories.

Examples of conflicts of interest involving special circumstances are:

• close collaboration in a professional context

• obvious friendship or enmity

• relationship of economic dependency

• superior/subordinate relationship

• someone involved in the matter in a way that may arouse doubts as to their ability to render an impartial judgement.

When a board meeting is considering decisions on announcement of grants and if a member, or a related person, can apply, the member may not participate in or attend discussions or decisions. If a member has participated in or attended at presentations, discussions or decisions the member cannot apply for grants in that call.

When a board meeting is considering decisions on grantees and if a member, or a related person, has applied for grants the member may not participate in or attend presentations, discussions or decisions.