Open letter to the Chairman and Commissioners of Grenada Integrity Commission

2020 Virtual Centre of Excellence Series

First of all, permit me to thank the Commission for its most gracious invitation extended to me to attend its recently concluded Virtual Centre of Excellence Senior Leadership and Management Regional Training Programme, sponsored by the Commonwealth Secretariat.    Congratulations!  It was a well scripted and choreographed performance and I became privy to some amazing, even startling information.  I am so pleased that, courtesy the Commission’s invitation, I was able to hear these pronouncements “straight from the horse’s mouth”!!   Among those particularly pertinent references for me were the following:-

• Grenada’s Integrity Commission had become a centre of excellence for anti-corruption work in the Caribbean.
• There is need for governance and transparency in fighting corruption.
• Grenada was the anti-corruption centre of the Caribbean and taken the lead in establishing the Virtual Centre of Excellence which was facilitating anti-corruption training.
• There was a presentation on Grenada’s Regime of Anti-corruption and Best practices.
• We heard thatthere were increasing concerns about Conflict of Interests and the introduction/implementation of a Code of Conduct.
• There was also an interesting presentation on Deploying Blockchain Technologies in the Fight against Corruption.

It was such “heavy stuff” that sometimes I felt as though “I can’t breathe”!!    I particularly look forward to more information about Grenada’s “anti-corruption best practices” and application as well as the Code of Conduct pertaining to “conflict of interests”.

I also noted the recommendation/suggestion from the Commonwealth Secretariat’s Adviser and Head of Public Sector Governance, Dr. Roger Koranteng, for meaningful engagement of civil society.  As a citizen and member of various collectives, I look forward to seeing the Commission’s plans and actions on more meaningful engagement and partnership and I look forward to playing my part.

• Conflict of Interests and Code of Conduct:

I was absolutely knocked over by the reference to the application of a Code of Conduct in addressing the issue of conflict of interest.  Permit me to remind the Commission of the concerns raised by the Grouping of Civil Society Statement in 2014 re “conflict of interests” and its reference to the Code of Conduct Schedule which is part of the Integrity in Public Life Act.    One can look at that statement in the context of a number of developments since then.   

• How is it that a former member of the Integrity Commission could have been the auditor of the state enterprise, Marketing and National Importing Board, which found itself at the centre of investigations ordered by the then Minister of Finance?
• How is it that a former Senator (and therefore a law maker) could have been simultaneously a lawmaker, a member of the Citizenship by Investment Committee reviewing applications and making recommendations and a local agent of the citizenship by investment programme?

1. Letter of June 12, 2020 to IC re Conflict of Interests:

I take this opportunity to follow-up on the above-referenced letter addressed to the Commission  on a number of concerns  re matters that, in my opinion, constituted conflict of interests:-

• A leading real estate agent being a member of the Planning Development and Control Authority which approves physical development projects;
• Star Telemed
• The View, Legacy Project Inc., Oyster Ventures and Star Development /Star Capital Development, Grenada

3.1.H.E. Ambassador Firer, Grenada’s Ambassador to the Russian Federation:

The letter also sought clarification on the relationship between the Integrity Commission and Grenada’s Ambassadors.  Of particular interest was Grenada’s Ambassador to the Russian Federation, H.E. Oleg Firer.  Observations were that “The boundaries in respect of his official role and the public interests vis-à-vis what appears to be full time pursuits of varied private interests are uncomfortably opaque”. 

The following roles and positions held by Grenada’s Ambassador to the Russian Federation are interesting:-

• World Health Organisation:  Representative of Grenada to the World Health Organisation/Executive Board, May 2019.
• Gainfy Foundation^[1]:  Advisor, Gainfy Foundation, March 2018; Gainfy is described as an “ Innovation-led healthcare company bringing life-changing technologies to the people who need them the most”
• Progressive Care^[2]:  Board Member, Progressive Care, October 2017; “Progressive Care provides prescription pharmaceuticals specializing in anti-retroviral patient management, long-term care, and DME.”

1. Eastern Caribbean Block Chain Association^[3]:   

H E is named as Board Member/Advisor, January 2018.  This entity describes itself as “promoting block chain innovation in the Eastern Caribbean” and it would appear that is H.E. is its only Board Member(?) and Advisor.  Interestingly, the colours of its logo mirrors that of the Eastern Caribbean Central Bank.

1. Main Objectives of ECBA^[4]:   

Among the objectives identified by the ECBA are the following:-

• Center of Expertise:  Become the center of expertise for creating regulatory, legal, administrative and other conditions for the application of technologies and practices

• Competence Center:  Scale and replicate the best practices and implementations of blockchain technology in the region, available to commercial and public organizations of the Eastern Caribbean
• Industry Standards:  Standards for industry processes, including ICO, cryptography, blockchain, preliminary evaluation of projects planning ICO or token initiatives                                                                                       
• Support and Marketing:  To assist participants and assist in the employment of government and commercial markets, as well as in negotiations with investors

The presentations delivered at the training which referenced the  block chain the technology emphasized the role that blockchain technology was expected to play in:_

• the efforts to fight corruption; and
•  in the roll out of the pilot digital currency initiative of the Eastern Caribbean Central Bank.

Noting the objectives of the ECBA, it seems reasonable to ask whether or not the ECBA has carved out a role for itself as the Eastern Caribbean adopts this technology.  Given H.E. Firer’s connections/role re the ECBA and the stated objectives of the ECBA, it seems reasonable to ask whether the ECBA presents opportunities for H.E. Firer to be exerting undue influence and whether these are opportunities for potential conflict of interests.  

I look forward to hearing from the Commission soonest in respect of the queries raised re conflict of interests concerns and request for information in my letter of June 12^th . 

Thank you for the opportunity, Commissioners to write to you on these matters and permit me to reiterate my appreciation  for the invitation to attend the regional training  put on by the Commission’s Centre of Excellence.

Sandra C A Ferguson

[1] https://www.crunchbase.com/organization/gainfy-foundation

[2] https://www.crunchbase.com/organization/progressive-care

[3] https://www.crunchbase.com/organization/eastern-caribbean-blockchain-association

[4] http://blockchainec.org/?page_id=99