Risk and Compliance aspects

Open Collective Europe: Grant Eligibility and Risk Assessment Policy

1. Introduction

Open Collective Europe (OCE) is committed to supporting initiatives that promote positive social change and a more just world. This policy outlines the criteria used to assess the eligibility of grant proposals and identify potential compliance risks associated with terrorism/extremism financing.

2. Grant Eligibility

OCE will prioritize proposals from initiatives that:

• Operate in accordance with the law.

• Do not support or glorify terrorist groups.

• Demonstrate responsible financial management practices, including transparent recordkeeping and reporting.

3. Compliance Risk Assessment

OCE will assess the potential compliance risk associated with a grant proposal using the following factors (by order of importance):

• Beneficiary Impact: Does the initiative's work demonstrably benefit its target communities?

• Public Statements: Does the initiative's public messaging avoid promoting violence or extremism?

• Transparency: Does the initiative publish financial statements and reports on its activities?

• Legality: Does the initiative's mission and activities align with legal frameworks and international law?

4. Contextual Considerations

OCE recognizes the importance of considering context when evaluating proposals. OCE will conduct due diligence to understand the specific context and actions of the initiative.

5. Information Sources

OCE will utilize various information sources to assess grant proposals, including (by order of importance):

• Initiative websites and reports

• Credible news sources and independent research organizations

• United Nations and human rights organization reports

• Government watchlists and sanctions lists

6. Limited Veto Power

OCE reserves the right to propose a veto of a grant proposal if a high compliance risk is identified based on the criteria outlined above. OCE will provide a clear and documented justification for the veto, outlining the specific concerns.

7. Appeals Process

Initiatives have the right to appeal a veto decision. The appeals process will be clearly communicated to all applicants.

8. Review and Revision

This policy will be reviewed and revised periodically to ensure its effectiveness and alignment with best practices.

9. Conclusion

OCE is committed to striking a balance between preventing terrorism financing and supporting legitimate initiatives working towards positive social change. This policy serves as a framework to achieve this objective.