CEE Hub Conflict of Interest (COI) Policy

Approved by the CEE Hub Steering Committee (May 2026)

Purpose

This policy establishes a shared standard for defining, disclosing, and managing conflicts of interest within the CEE Hub governance and decision-making processes. It aims to ensure transparency, fairness, and integrity across all Hub-related activities, in alignment with broader Wikimedia movement values and practices.

Principles

CEE Hub decision-making should be guided by:

Transparency - Openly disclosing relevant interests
Integrity - Acting in the best interest of the Hub and movement
Accountability - Taking responsibility for managing conflicts appropriately
Proportionality - Applying measures that are appropriate to the level of risk

Scope

This policy applies to:

Members of the CEE Hub Steering Committee (SC)
Affiliates when collaborating or cooperating with the CEE Hub or its activities
All CEE Hub-related bodies
Individuals participating in Hub processes, including advisory, evaluation, and selection roles
CEE Hub staff

It covers all contexts where impartial decision-making is expected, including:

Grantmaking and recommendations
Partnerships and collaborations
Hiring, contracting, and procurement
Event programming and participation decisions

Definition of conflict of interest

A conflict of interest is any situation in which an individual’s personal, professional, or financial interests, or the interests of any third party, could interfere with, or reasonably be perceived to interfere with, their ability to act in the best interests of the CEE Hub as the collective of all community members and editors that it unites and represents in an honest, open, and equitable manner.

This definition aligns with standards used by the Wikimedia Foundation and broader nonprofit governance practices, recognizing:

Actual conflicts - a direct and existing conflict
Potential conflicts - a situation that could develop into a conflict
Perceived conflicts - situations that may appear to others as a conflict, even if no actual conflict exists

Conflicts of interest may include, but are not limited to:

Involvement in multiple bodies, boards, committees, or entities with competing interests
Participation in decisions affecting one’s own organization, project, or funding request
Close personal or professional relationships
Financial or material interests

Rules & practices

1. Disclosure
All participants must proactively disclose any actual, potential, or perceived conflicts of interest:

At the start of relevant discussions or decision-making processes
When circumstances change

2. Recusal & participation

Individuals with a conflict should recuse themselves from final decision-making (e.g., voting or consensus formation)
Participation in discussions may be allowed only for clarification purposes, where appropriate and agreed upon by the group:
- Conflicted members may answer factual questions only.
- They should not advocate.
- They leave the discussion before deliberation, whether it is an online or offline meeting.

3. Collective oversight

The SC (or relevant body) is collectively responsible for identifying and managing conflicts
In cases of ambiguity, the SC determines appropriate mitigation measures

4. Documentation

Disclosures and recusals should be documented in a consistent manner (e.g., meeting notes or decision records)

5. Good faith & responsibility

This policy relies on good-faith participation
Failure to disclose relevant conflicts may be addressed collectively by the SC, with appropriate corrective measures, such as requesting retroactive disclosure, documenting the issue, limiting participation in future decisions, or applying other proportionate steps agreed by the SC.

Alignment

This policy aligns with the principles and expectations of the Wikimedia Foundation and the broader Wikimedia movement, while remaining adapted to the operational realities of the CEE Hub. Only the SC has the authority to update or amend the policy, and a majority vote of its members must approve any such changes. Affiliates are encouraged to adopt conflict of interest policies that align with the standards and principles established by this policy.