Dear friends,

            Summary of discussions: conflict of interest within the CCM, we all known about the leader of the nation / project implementer especially the private fund implementations. While I gone through the studies about the government as a primary implementation, the mechanism may be constrained by the politician and other power leaders of that area. The CCM have to adopt that what they instruct to do. Due to this nature the primary recipients/sub recipients/local fund agency may have to adopt the regulations as framed by these politicians/powerful persons but, the partners of the global fund are not depend any political party, they may not be a elected member of any organization. At this juncture, I clearly express my view that the global fund have to give clear cut policies , about the selection of the global fund’s implementing agencies, their eligible criteria, able to conducted the programme more over those organization are working within the pandemic disease like AIDS/malaria/tuber closes further my opinion is that, the my global fund’s secretariat should frame a specific rules & regulation, planning of implementations, monitoring & evaluation and etc and it should be strictly followed by the my global fund.

            In some CCM member may have availed the global fund at their working area. I feel that, these CCM members may or may not encourage the new principle recipients/ sub recipients LFA s. At this point my global fund may seek the whole project applicants analysis those and advice to the CCM as per the merits of the applicants. This has to be monitor by the secretaries of the my global fund

Thanking you,

C.RAVICHANDRAN

India.

When does a conflict of interests arise?

1.      Most conflicts of interests arise when a member of the CCM applies to become a Principal Recipient (PR) or Sub-Recipient (SR). This kind of member can easily dominate the decisions of CCM during selection process, as well as oversight during implementation

2.      If CCM members are sub-recipients of the Global Fund grant, there will always be conflict of interest during the process of reviewing proposals. Members of the CCM could be influenced to favour them thereby affecting the chances of others wanting to benefit from the grant.

3.      Conflicts of interest are often created by members of the CCM Executive Board through ignorance (unconsciously, through incompetence) or deliberately (for financial gains).

4.      This question underlines the representation of the public sector in CCM; civil society is usually not a principal recipient, but a sub-recipient, represented by NGOs that can seek and obtain CCM membership.

The need for stricter guidelines

5.      The clear-cut solution is that such a member should resign from the CCM before a call for proposals. However, this can mean that a CCM may face losing qualified people from its membership.

6.      When we talk of clearer policies and guidelines, we mean precise, updated and genuine information that will put people in the know so that they act appropriately.

7.      Participation in the CCM should have clearer norms in terms of who receives the funds. Conflict handled properly, leads to creativity.

8.      Conflicts of interests very much depend on the rules that each CCM sets, so the Global Fund should ensure that the proposal that is submitted corresponds to the national plan of action and that does not “belong” to a particular organization.

A PR or SR’s position in the grant life-cycle

9.      A PR or SR should not remain in a Chair or Vice-Chair position; they should not have the right to vote on issues related to their own organization's interests. 

10. It is already a challenge in some countries that the Chair is from the government while the PR is from another government department or ministry.

11. One solution could be that the Ministry of Finance is a member of the CCM and the Ministry of Health implements the program. This way, the conflicts of interest can be better addressed.

Mechanisms to deal with conflict of interests should be established

12. Instead of sub-recipients sitting on a CCM, they should be accommodated in the disease specific committees (the Inter-agency Coordinating Committees) where they could ensure their interests are taken care of.

13. The policy of preventing conflict of interest exists – it is written in program agreements – but the mechanisms to curb conflicts of interests do not. The Global Fund is obliged to establish these.

14. Proper monitoring and regular evaluation of the CCMs is needed in order to ensure that a PR is not linked to or a puppet of the CCM, and vice versa.

15. The roles of the CCM, PR and SR should be clearly defined to ensure that they work to achieve the country proposal objectives and not to serve a particular organization.

Technical Assistance

16. It is important to provide technical assistance to CCM members in order to improve their skills in good governance and management.

Increase transparency

17. There should be a committee to manage the conflicts of interests whenever the need arises. The members of this committee would be appointed on the basis of impartiality, ethics and professionalism.

18. Decisions taken at general CCM meetings should be published.

Contributions by:

English:    Dr Mohammad Fareed - Berhanu Tesfaye - Ashish Srivastava  (2) (3) (4) (5) (6) - Jane - C.Ravichandran - Bangkit - Dr Hilary Ene Otimanam - Nformi Edward Komusong - Thiongo - Rele.

Spanish:   Alejandra Victoria Portatadino - Ada Maldonado (2) - Hugo Rolando Valladares Morales - Gracia Violeta Ross - Pablo Neida.

French:    Tambalou - Kouassi - Stanli83 - Malakona - Zongo Issa.

Russian:   Alexander Kahn - Vitali

Dear e-forum friends,

            Regarding the conflicts of interest with in the CCM, my view ie, the member of CCM is a principle recipient, sub-recipient of LFA there is no problem, it those members may not dominate the other global fund’s partners because they may dominate the other partners of the global fund due to the advantage of members of the CCM. There should be a clear cut rules & regulations, polices of implementation process, selection of global fund’s partners approach and strategies for implementation framed by the global fund’s secretariat this is an unique and should not give any relaxation geographically. The CCm members should serve accordance with country health department and total country’s health budget the member of CCM have to close contact with the local NGOs/PRs/SPR,/LFAs etc. with flexible, there should be a transparency in organization structure, financial background documentation & reporting and evaluation methodology. There all should be framed and follow by the secretariat of the global fund. The CCM and its members have to communicate frequently with the partners of the global fund for progressive implementation of the program with quantitative improvement I feel that global fund secretariat have to set clear policies and guidelines to mitigate the inherent conflict  of interest.

Thank you,

C.Ravichandran

India.