Financial support should enable independent review. It must never determine the result of that review.
This Funding Transparency framework explains how the International Sanctions Delisting Commission (“ISDC”) approaches financial support, donor independence, case-related funding, disclosure and safeguards intended to protect the integrity of its institutional work.
Transparency Principle
ISDC recognizes that the source and structure of institutional funding can affect public confidence in research and sanctions review.
Transparency is therefore not limited to identifying who provides financial support. It also requires clarity concerning what influence, if any, a funder may exercise over the work supported by that funding.
ISDC seeks to maintain a structure in which funding supports institutional capacity without purchasing access to findings, recommendations or case-specific outcomes.
Know the Source
Material sources of financial support should be identifiable to ISDC and assessed where necessary for legal, ethical, reputational or independence concerns.
Understand the Purpose
Funding arrangements should make clear whether support is institutional, project-based, research-related or connected with a specific review process.
Separate Funding from Findings
Financial support must not entitle a funder to determine the evidence considered, analytical reasoning applied or recommendation reached.
Disclose What Matters
Material funding relationships should be disclosed where transparency is necessary to understand the independence of institutional work.
No financial contribution gives a donor, applicant, sponsor or other contributor the right to direct an ISDC conclusion.
Forms of Funding
ISDC may receive or consider different forms of financial or in-kind support. The appropriate transparency and independence safeguards may differ depending on the structure and purpose of that support.
Case-Related Funding
Sanctions review can require substantial research, evidence processing, legal analysis, document review, translation, technical support and institutional resources.
A person or organization with an interest in a review may therefore contribute toward legitimate costs associated with the review process, subject to appropriate independence safeguards.
Payment of review-related costs does not convert an ISDC assessment into advocacy on behalf of the payer and does not guarantee that ISDC will open, continue, publish or conclude a review in a particular manner.
The obligation to pay for research capacity and the authority to determine research conclusions are separate. The first may be funded. The second is not for sale.
Applicant-Funded Reviews
Where costs connected with a review are funded by the person or entity requesting reconsideration, ISDC should preserve a clear distinction between the funding relationship and the analytical relationship.
The applicant may provide information, documents, legal arguments and other relevant material. ISDC may nevertheless:
- reject or give limited weight to submitted material;
- seek independent or contrary evidence;
- consider information adverse to the applicant’s position;
- reach a conclusion different from the applicant’s requested outcome;
- determine that the existing designation remains justified;
- determine that the evidence is insufficient to reach a conclusion.
What Funding Cannot Buy
Funding cannot purchase a recommendation for delisting, maintaining a designation or any other predetermined result.
A funder cannot prevent ISDC from considering relevant adverse, contradictory or independently obtained evidence.
A contributor does not receive the authority to approve, rewrite or suppress ISDC findings.
Funding a review does not transfer ownership of the analysis, methodology or institutional recommendation.
Evidence provided by a funder is subject to the same verification and analytical scrutiny applied to other material.
Legitimate confidentiality concerns may be considered, but a funder may not require material findings to be distorted for reputational convenience.
Acceptance of Funding
ISDC may decline financial or in-kind support where acceptance would create legal, ethical, operational, sanctions-compliance, reputational or institutional independence concerns.
The source of funding may therefore be assessed before acceptance, particularly where the funding is substantial, unusually restricted, connected with an active review or otherwise capable of raising a reasonable question concerning independence.
Funding Review Process
Determine the source, nature and intended purpose of the proposed funding or in-kind support.
Consider legal restrictions, sanctions-related concerns, institutional conflicts and relevant reputational risks.
Determine whether the support is general, project-specific, case-related, restricted or otherwise requires enhanced transparency.
Establish appropriate separation between financial support and substantive research, review or editorial decisions.
Determine whether the relationship should be identified in a public institutional record, project publication or specific case material.
Public Disclosure Framework
ISDC seeks to disclose funding relationships at a level proportionate to their relevance to public understanding of institutional independence.
Material sources of general institutional support may be identified through appropriate public transparency disclosures.
Material financial support for a defined research or public project may be identified in connection with that project.
Where financing of a specific sanctions review is material to understanding the review’s independence, an appropriate disclosure may accompany the public case record.
Limited confidentiality may be considered where there is a legitimate legal, privacy, security or institutional reason, provided that confidentiality does not conceal an unacceptable conflict of interest.
Disclosure Does Not Equal Endorsement
Identification of a donor, contributor or funding source should not be interpreted as endorsement by that party of every ISDC publication or conclusion.
Similarly, acceptance of lawful funding does not imply that ISDC endorses every activity, statement or position associated with the funding source.
Donor Independence
Donors and contributors should not participate in ISDC decision-making merely because they provide financial support.
Where a funder separately possesses relevant expertise or evidence, that contribution should be assessed according to its substantive value and not according to the financial relationship.
Funding and Conflicts of Interest
A funding relationship may create an actual, potential or perceived conflict of interest.
Where that occurs, the relationship should be assessed under ISDC’s Conflict of Interest Policy and may require disclosure, independent review, restricted participation or other safeguards.
Restricted Funding
A funder may identify a legitimate purpose for which financial support is provided, such as technology, research, translation, public access, institutional capacity or a defined project.
Restrictions become incompatible with institutional independence where they attempt to control substantive conclusions, exclude relevant evidence, require a predetermined recommendation or otherwise interfere with the integrity of an ISDC review.
In-Kind Contributions
Transparency principles may apply to material non-cash contributions as well as direct financial payments.
Examples may include professional services, data access, research resources, technology, facilities, translation or other support with material institutional value.
Anonymous Funding
ISDC generally favors identifiable sources of material financial support.
Anonymous or undisclosed funding may require heightened assessment, particularly where the identity of the ultimate source is relevant to sanctions compliance, conflict-of-interest analysis or institutional independence.
ISDC may decline funding where the identity of a material source cannot be established to a level reasonably necessary for institutional review.
Intermediaries and Ultimate Funding Sources
The use of an intermediary does not necessarily determine the true source of financial support.
Where relevant, ISDC may consider whether funds are being provided on behalf of another person or organization and whether the identity of an ultimate funding source should be established before support is accepted.
Financial Transparency and Sanctions Compliance
Funding transparency does not replace applicable legal or compliance obligations.
Financial relationships may require separate consideration of applicable sanctions restrictions, payment controls, financial regulations or other legal requirements.
ISDC may refuse or suspend a financial arrangement where it cannot be conducted consistently with applicable obligations.
Changes in Funding Relationships
Transparency assessment may continue after funding is initially accepted.
A material change in ownership, control, purpose, conditions or source of funding may require reassessment or additional disclosure.
Public Transparency Record
ISDC may maintain or publish institutional information concerning material funding sources, categories of support or relevant funding relationships where doing so assists public understanding of the institution’s independence.
The form and level of disclosure may differ according to the scale, structure and relevance of the funding relationship.
Would knowledge of this funding relationship materially assist a reasonable reader in evaluating the independence of the work? If so, disclosure should ordinarily be considered.
Relationship to Other ISDC Standards
Funding transparency forms part of a wider institutional framework and should be read together with ISDC’s Conflict of Interest Policy, Institutional Independence standards, Editorial Standards and other applicable review policies.
Transparency should make it possible to understand who supports the institution without giving those who support it ownership of its judgment.
ISDC therefore distinguishes between financing the capacity to conduct independent review and controlling the conclusions produced by that review.