Polityka Zarządzania Konfliktem Interesów dla członków i członkiń organów statutowych Stowarzyszenia Wikimedia Polska/Draft COI Policy Guide

Draft COI Policy Guide for Wikimedia Polska

Premise
Wikimedia Polska is an affiliate of the Wikimedia Movement. It is expected to uphold the general guiding principles of the Wikimedia Foundation and the wider Movement.

Current Policy
Wikimedia Polska COI Policy (Polish)

What Wikimedia Polska Has Already Covered Well:

Clear definitions and scope of conflict of interest (COI).
Focus on statutory bodies (Management Board and Audit Committee).
Written declarations of no conflict when concluding relevant contracts.
Immediate disclosure obligations.
Rules for exclusion from decision-making when conflicted.
Defined sanctions (e.g., referral to Peer Court).
Public availability of the policy and obligation for members to comply.

Examples from Other Affiliates:

Suggestions for Conflict of Interest (COI) Policy Improvement

Aspect	Current Wikimedia Polska Policy	Suggested Enhancement
Coverage	Applies only to statutory bodies (Board and Audit Committee)	Extend coverage to include staff, volunteers, contractors, grant recipients, and any individuals receiving resources or funds from Wikimedia Polska or its affiliates.
Types of Conflicts	Focused on contracts over PLN 20,000 in 12 months	Broaden to include: indirect financial interests, familial or romantic relationships, positions in other organizations, gifts, and personal/professional affiliations.
Annual/Periodic General Declarations	No provision for periodic declarations; only contract-related disclosures required	Introduce mandatory annual declarations of interest for all covered individuals, regardless of contract activity. This ensures ongoing transparency and aligns with international best practice.
Designated Oversight Role or Body	No assigned officer or committee for oversight	Assign responsibility to a designated officer (e.g., Secretary or Chair) or a dedicated COI Committee for collecting disclosures, maintaining the register, managing assessments, and advising on mitigation steps.
Documentation & Record Keeping	No requirement for maintaining a Register of Interests	Create and maintain a formal, updated Register of Interests, accessible to relevant oversight bodies. Disclosures should also be summarized in meeting minutes where relevant decisions are made.
Public Transparency	Policy is publicly available; no public record of interests	Consider publishing a summary of interests of Board and Audit Committee members annually to build trust and accountability.
Sanctions and Enforcement Mechanisms	Only mentions reporting to the Peer Court	Introduce a graduated sanction framework, such as warnings, temporary exclusion, suspension, or removal from roles, with internal investigation procedures prior to Peer Court referral.
Gifts and Hospitality	Not addressed	Include specific provisions on gifts and hospitality, with defined thresholds for declaration and reporting. Clarify permissible and impermissible gifts to prevent undue influence.
Scope of Definition (Related Parties)	Uses broad term “personal interests” only	Expand definitions to explicitly include related persons, such as spouses, partners, dependents, and close associates, whose interests can create a COI.
Training and Awareness	Members to "familiarize themselves" with the policy	Introduce mandatory training or onboarding sessions for new Board, staff, and volunteers. Periodic refresher courses should be held, especially after policy updates.
Decision-Making and Recusal Procedures	Applies only to decisions involving specific contracts	Formalize recusal processes for meetings, grant evaluations, or any decision-making scenarios involving actual or perceived conflicts of interest.
Review and Update of the Policy	No mention of review	Introduce a regular review cycle (e.g., every 2 years), with stakeholder feedback and alignment with Movement-wide guidance.
Policy Scope Document	Focuses on contractual relationships	Develop a comprehensive COI policy document or handbook, with the current contract policy embedded as a section, applicable across all Wikimedia Polska activities.