Conflict of Interest Policy

DAKSH has adopted this Conflict of Interest Policy (“Policy”) to avoid and mitigate Conflicts of Interest or the appearance of Conflicts of Interest. This Policy applies to all DAKSH Personnel, including Employees and Consultants. DAKSH Personnel are required to abstain from acting on DAKSH’s behalf in matters where a Conflict of Interest, or the appearance of a Conflict of Interest, exists. DAKSH Personnel may not accept travel, gifts, or entertainment from a third party that will unduly influence their responsibilities. DAKSH Personnel are required to disclose before entering into the relationships, or immediately upon becoming aware of any actual or potential Conflicts of Interest.

Applicability

This Policy applies to all DAKSH Personnel, including Employees and Consultants.

Definitions

Employee: Refers to an individual employed by DAKSH

Conflict of Interest: Refers to when an individual has a personal interest to the extent that it affects, or might provide an incentive to affect, the individual’s performance of duties at DAKSH. The term Conflict of Interest includes activities that create actual or potential conflicts of interest and includes the activities that create the appearance of a conflict of interest.

Consultant: Refers to a person who has been engaged by DAKSH for a fee or other consideration.

General Policy

DAKSH Personnel should always perform their responsibilities in the best interests of DAKSH. DAKSH Personnel should be free from influences that may benefit themselves or third-parties when working for DAKSH.

DAKSH Personnel must abstain from acting on behalf of DAKSH in matters where a Conflict of Interest may exist. They should also avoid any situation that might lead their loyalties to become divided in a manner that creates a Conflict of Interest or the appearance of a Conflict of Interest.

DAKSH Personnel must also ensure that any work they perform outside of their duties in DAKSH do not conflict with DAKSH’s or their individual obligations, under any funding agreement, contract, or their terms of engagement with DAKSH.

DAKSH Personnel must seek prior permission from the Programme Director before agreeing to begin any of the following activities that relate to their responsibilities at DAKSH:

• Resulting in compensation in excess of Rs. 25,000;
• Appointments to a fiduciary board; or
• Formal paid or unpaid advisory roles for any government or government entity.

DAKSH Personnel should ensure that their activities outside DAKSH are their own and not imputed to DAKSH. If any DAKSH Personnel engage in activities in which they must make decisions that impact DAKSH (e.g., being on the board of entity making a grant to DAKSH or an organisation entering into a contract with DAKSH) must recuse themselves from any deliberations related to DAKSH.

DAKSH Personnel may not, except with advance written approval from the Programme Director, knowingly have a material interest in:

• Any entity which is a major supplier,or service provider to DAKSH;
• Any organizations that directly compete with the core mission of DAKSH; or
• An organisation that directly funds the work of DAKSH

“Having a material interest in a third party”may include:

• Serving as a director, officer, or employee of a third party (a person or entity)
• Performing work or services for, or receiving compensation (including consulting fees, substantial gifts, entertainment, services, travel reimbursement, or loans) for a third party;
• Being materially indebted to a third party;
• Having a personal contract or understanding with a third party

DAKSH Personnel are prohibited from accepting gifts valued in excess of Rs. 25,000 (“gifts”) from any individuals or organisations that DAKSH is or has been engaged with. Gifts may include travel, meals, lodging, entertainment, cash or cash equivalents, physical objects or services.This prohibition is not intended to apply to travel, meals, entertainment or the like for DAKSH work, including attendance at conferences, outreach for  funding, solicitation and stewardship and research-related travel. It is intended to apply to travel, meals, entertainment and the like (received other than from family and friends) that have no purpose for DAKSH or the DAKSH component is not significant or the social component does not comport with the overall professional standard of avoiding actual or apparent conflicts of interest.