Here you will find the Knowledge Foundation’s rules on conflicts of interest and secondary activities. The rules are intended to ensure objectivity, impartiality, and trust in the Foundation’s activities and apply to everyone who works within or on behalf of the Knowledge Foundation.
Conflict of interest
Purpose
Conflicts of interest refer to doubts about impartiality. Rules on conflicts of interest aim to ensure objectivity and impartiality when handling matters. The rules also aim to build trust among those affected by the matters and among the public.
Who is subject?
The Knowledge Foundation’s rules on conflicts of interest apply to members of the Board, members of the Capital Committee, members of expert groups and assessment groups, employees, and external experts and consultants engaged by the Foundation.
Legislation
The Knowledge Foundation is not subject to the provisions on conflicts of interest in the Administrative Procedure Act (2017:900). The Administrative Procedure Act applies to government agencies. However, the Knowledge Foundation’s activities have a strong public character and against this background, the Knowledge Foundation applies the principles on conflicts of interest expressed in the Administrative Procedure Act to ensure objectivity, impartiality and trust in its activities.
The Knowledge Foundation was established by a decision of the Swedish Parliament in 1994, and public funds were provided as its founding capital. The appendix to the Public Access to Information and Secrecy Act (SFS 2009:400) states that the Knowledge Foundation is subject to the provisions of the Freedom of the Press Act concerning the right of access to documents.
Definition
A person who is to handle a matter has a conflict of interest
- if the matter concerns the person themselves or their spouse, cohabiting partner, parent, child, sibling, or another person close to them, or if the outcome of the matter can be expected to benefit or harm the person themselves or someone close to them;
- if the person or someone close to them is or has been a legal representative or representative of the person concerned by the matter, or of someone who can expect to benefit or suffer harm from its outcome;
- if the person or someone close to them has assisted someone in the matter, with or without payment; or
- if there is any other specific circumstance that could undermine trust in the person’s objectivity or impartiality in the matter.
Reporting conflicts of interest
Anyone who is aware of a circumstance that may constitute a conflict of interest for themselves must report it on their own initiative. Anyone who is aware of a circumstance that may constitute a conflict of interest for a person involved in handling a matter must report it if that person has not already drawn attention to the circumstance. Employees must inform their manager. The CEO and Board members must inform the Chair of the Board. The Chair of the Board must inform the Vice Chair or the Board as a whole. Members of the Capital Committee must inform the Chair of the Committee. The Chair of the Capital Committee must inform the Vice Chair or the Committee as a whole. Discussions about conflicts of interest must be conducted in a spirit of openness.
Assessors, experts, and consultants engaged to handle matters on behalf of the Knowledge Foundation must, at the start of their assignment, confirm in writing that no conflicts of interest exist and that they will immediately report any conflict of interest that arises during the assignment to the Knowledge Foundation. Before assessors, experts, or consultants are engaged for a specific matter, the Foundation’s staff must actively ask whether there are any circumstances that may constitute a conflict of interest. If a conflict of interest is considered to exist, the assignment must not be given to the person concerned.
Measures in the event of conflicts of interest
A person who has a conflict of interest must not handle the matter. They may not participate in the preparation or the decision-making process regarding the matter. A person who has a conflict of interest must leave the room while the matter is being handled, discussed, and decided.
A check for conflicts of interest must always be included on the agenda for meetings of the Board, the Capital Committee, and expert and assessment groups.
If the Chair has a conflict of interest, a separate meeting chair may be appointed for the matter concerned.
If the CEO has a conflict of interest in a matter, the Board must decide on the matter.
If the conflict of interest is clearly of no significance, the CEO, in the case of another employee, or the Board, in the case of a Board member or the CEO, may decide that the person may nevertheless participate in handling and deciding the matter. Conflicts of interest must be recorded in the minutes or, in the case of employees, assessors, experts and consultants, in another document added to the case file.
Secondary activities, including assignments
Secondary activities refer to anything a person may undertake in addition to their employment, regardless of whether the activity generates any income. This may include positions of trust, involvement in an association, employment, or an assignment for another organization. Rules on secondary activities aim to maintain trust in the Knowledge Foundation’s activities, employees, and members. Foundations are not required to report Board members’ assignments in their annual report.
Employees’ secondary activity (Foundation staff)
The Knowledge Foundation’s employment contracts must include provisions on secondary activities.
An employee of the Knowledge Foundation must not have other employment, assignments, or secondary activities that could undermine their loyalty, trust in their own or another employee’s objectivity and impartiality or otherwise harm the Knowledge Foundation.
An employee who intends to take on other employment, an assignment or a secondary activity must first obtain the CEO’s written consent.
Assignments held by Board members
Board members must not hold assignments or engage in activities that could undermine trust in their objectivity or impartiality in their work on the Board.
Board members must inform the Chair of the Board of any positions or other roles, such as legal representative, in companies, government agencies or organisations. The CEO maintains a register of these assignments and provides updated information to Board members each year in December.
Assignments held by members of the Capital Committee (including members employed by the Foundation)
Members of the Capital Committee must not hold assignments or engage in activities that could undermine trust in their objectivity or impartiality in their work on the Capital Committee.
Members of the Capital Committee must inform the Chair of the Committee of any board positions or other roles, such as legal representative, in companies, government agencies, or other organisations. Business relationships or ownership interests of a scale that could give rise to a conflict of interest must also be reported to the Chair of the Committee. The CEO maintains a register of these assignments and provides updated information to all Committee members twice a year.