Every GS Staff Member acknowledges the duty to promptly declare and disclose to GS any actual, potential, or perceived conflicts of interest that may arise. They are expected to recuse themselves from making conflicted decisions and/or accept GS's mitigation strategies in accordance with this Policy. Specifically, there can be:
- Transactional conflicts: A duty to disclose any interest in a proposed or existing transaction or arrangement with any of GS’s stakeholders.
- Situational conflicts: A general duty to avoid conflicts of interest. To clarify, any interest held by a GS Staff Member with a partner is deemed a conflict and must be disclosed in adherence to this Policy.
To ensure the proper disclosure of potential conflicts of interest, all Staff Members are required to complete an Acknowledgment and Disclosure Statement Form in annex 1. This involves:
- Confirming they are not aware of any conflict, other than those already disclosed, that exists between their role and their personal circumstances or other interests.
- Affirming their commitment to updating the form annually or sooner if any changes occur.
Confirming their commitment to declare any conflict that arises in the future.Every GS Staff Member acknowledges the duty to promptly declare and disclose to GS any actual, potential, or perceived conflicts of interest that may arise. They are expected to recuse themselves from making conflicted decisions and/or accept GS's mitigation strategies in accordance with this Policy. Specifically, there can be:
- Transactional conflicts: A duty to disclose any interest in a proposed or existing transaction or arrangement with any of GS’s stakeholders.
- Situational conflicts: A general duty to avoid conflicts of interest. To clarify, any interest, position, mandate or responsibility held by a GS Staff Member with a partner or any other organization is deemed a conflict and must be disclosed in adherence to this Policy.
To ensure the proper disclosure of potential conflicts of interest, all Staff Members are required to complete an Acknowledgment and Disclosure Statement Form in annex 1. This involves:
- Confirming they are not aware of any conflict, other than those already disclosed, that exists between their role and their personal circumstances or other interests.
- Affirming their commitment to updating the form annually or sooner if any changes occur.
- Confirming their commitment to declare any conflict that arises in the future.
At least annually or when any material changes occur, each GS Staff Member must review the information related to them and declare that the information is correct or make a further declaration, if necessary, by completing the Acknowledgment and Disclosure Statement Form in annex 1 or in the HR application if available.
GS Staff Member holds the responsibility to determine which matters to declare. However, if uncertainty arises, they should:
- Reach out to their line manager, who will escalate to the Head of Legal.
- Reach out directly to the Head of Legal.
- Make a declaration using the Acknowledgment and Disclosure Statement Form in annex 1.
During their daily responsibilities, if a GS Staff Member identifies an actual or potential conflict,
they should promptly notify their line manager or reach out directly to the Head of Legal via email. This notification should include completion of the Conflict Declaration Form in annex 1. Following discussion with the conflicted staff member, the line manager will forward the conflict notification email to the Head of Legal.
Similarly, if a GS Staff Member becomes aware that another Staff Member has an actual or potential conflict that has not been disclosed, they should follow the same procedure above which must be treated confidential with their identity protected.
The information provided by GS Staff Members regarding this Policy will be recorded in the conflict of interest register and maintained confidentially by the legal team. Access will be granted to authorized individuals strictly on a need-to-know basis.