Governance and Oversight Committee
31 December 2016
Consultation on EITI
Constituency governance
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Survey questions and background
1 Membership and Constituencies
Questions to consider:
1. Should there be changes to the process of registering members of the EITI Members’
Association? In particular,
a. Who should be responsible for registering members? Is the current practice adequate,
that the Secretariat approaches the Constituencies ahead of each Members’ Meeting
asking them to ensure that the Members’ registry is updated?
b. Would it be preferable if Constituency coordinators, acting on behalf of the
Constituency, ensured that their Constituency has an up-to-date membership registry?
2. Would you support a change to the quorum rules for the Members’ Meeting, making it possible
for a quorate meeting to be established with a smaller number of members present? (This would
require a change to the Articles of Association.)
3. Do you have any other comments about membership and constituencies?
Background
The governing and highest decision-making body of the EITI is the EITI Members’ Meeting (Article 7.1) and
the Members’ Meeting is comprised of the Members of the Association (Article 7.2). The Members’
Meeting approves the accounts and elects the EITI Board and its Chair, among other things (Article 8.1).
The Articles of Association defines a Member of the EITI as “a personal representative of a country
(meaning state), company, organisation or legal entity that is appointed by a Constituency…” (Article 5.1). A
Constituency “may replace any of its own appointed Members any time” and “shall inform the EITI
Secretariat of its Members at any time” (Article 5.4). Each Constituency decides on its rules governing
appointments of Members of the EITI Association (Article 5.3). For the Members’ Meeting to be quorate,
“half of the Members” of the EITI and “must include at least one third of the Members’ from each
Constituency” need to be present.
Article 5.3 sets limits to membership in each Constituency:
i)
ii)
“From the Constituency of Countries, up to one representative from each Implementing
Country and each Supporting Country (or their unions);
From the Constituency of Companies, up to one representative from each company and
associations representing them, and a maximum of five representatives from Institutional
Investors;
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iii)
From the Constituency of Civil Society Organisations, up to one representative from each Civil
Society Organisation.”
As Article 5.3 notes, the Constituency of Countries is divided into two sub-Constituencies: Implementing
and Supporting Countries. Constituencies have also divided themselves into sub-Constituencies and subgroups within these sub-Constituencies.
The EITI International Secretariat keeps a list of the Members of the EITI. Ahead of each Members’
Meeting, the Secretariat has asked the Constituencies and sub-Constituencies to update their membership.
It has at times been challenging for the Secretariat to track down and obtain responses from Members. It
has thus been difficult to establish the membership. This is important, as it has consequences for the
Members’ Meeting.
Article 7.7 sets out the rules for quorum at the Members’ Meeting: “The quorum of a Members’ Meeting
shall be a minimum of half of the Members, and must include at least one third of the Members from each
Constituency.” As it is quite possible that fewer than half of hundreds of members would be able to travel
across the world to attend an EITI Members’ Meeting, the EITI Board may wish to propose amendments to
the way in which quorum is established at the Members’ Meeting. Somewhat dependent on how well the
Constituencies keep the register up-to-date, there is a significant risk that a future Members’ Meeting will
not be quorate.
2 Nominations procedures
Questions to consider:
4. Should the EITI propose more guidance for how the Constituencies organise Board nominations
procedures? For example:
a. What should be expected of Constituencies regarding nomination processes to achieve
the most effective outcomes, including representation and diversity of skills and
expertise?
b. Should Constituencies be asked/required to elect their nominees through a vote?
c. Should Constituencies be asked/required to publish a statement ahead of each
Members’ Meeting explaining to the Members how the Constituency is organised? For
an example see Exhibit B “Constituency Operations Statement” in the Global Fund to
Fight HIV-AIDS, TBC and Malaria’s Guidelines on Constituency Processes.
5. Should anyone, possibly the International Secretariat, be given a mandate to vet nominations?
(This could require a change to the Articles of Association.)
If so:
a. What criteria should the vetting follow?
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b. Is it right that the International Secretariat or the EITI Board have the final say on a
Constituency’s nomination process?
6. Do you have any other comments about membership and constituencies?
Background
The executive body of the EITI is the EITI Board. It is elected by the Members’ Meeting on nomination from
the Constituencies. How Constituencies nominate their Board members and alternates varies from
Constituency to Constituency and is explained in each Constituency’s guidelines. In cases where
Constituencies have informally divided themselves into sub-Constituencies, these often have also
developed their own guidelines. Problems may occur if there are disagreements within the Constituencies.
The Articles of Association states that “The EITI Members’ Meeting shall… elect the Members, and
Alternates for each Member, of the Board, on nominations from the Constituencies.” (Article 8). Article 9.4
adds that “The Constituencies may nominate, and the EITI Members’ Meeting may elect, one alternate
Board Member (an “Alternate”) for each Board Member that the Constituency has nominated”. It is thus
the Constituencies’ responsibility to nominate Board Members.
The report in 2006 of the International Advisory Group, on which much of the EITI’s governance structure is
built, said that “Each of the Constituencies should agree how they wish to be represented on the [EITI
Board]. This requires prior consideration by each Constituency of how they define those eligible i) to be
selected as representatives; and ii) to be involved in the selection process”. To help Constituencies and subConstituencies in this process, the EITI Board agreed at its meeting in 2011 that the following principles
should apply:
a. The process that the different Constituencies follow should be open and transparent.
b. Information on the processes should be made available on the EITI website, including a
contact person for any stakeholder wishing to be involved.
c. The process should be flexible and open to new members. The Constituencies should bear
in mind achieving a balance between the need for continuity against the need for renewal
and broadening of the ownership of the EITI.
d. Recognising the important role that the EITI Board has for the EITI, countries and
organisations are encouraged to be represented at senior level.
e. The Constituencies should bear in mind how important it is that the EITI Association and
Board are representative of all of the EITI’s stakeholders. It is, for example, expected that
countries from different regions, companies, and civil society organisations with strong
links to different regions be represented. While it may not be possible to determine that an
international body such as the EITI Board be gender balanced, the Constituency groups are
encouraged to ensure that both genders are adequately represented.
f.
Constituencies should also bear in mind that it is beneficial to identify the range of skills
that will benefit the constituency and the organisation more broadly and seek to recruit
board members that will contribute those skills that are needed.
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The processes for agreeing nominations vary considerably between the Constituencies:
The
…is divided
Constituency into…
of…
… which conduct their nominations processes in the following manner:
Countries
Implementing
Countries,
subdivided
into 6 regions
Elections are held in each region, with each country being able to vote for certain candidates to serve on the Board. The
International Secretariat supports the process.
Supporting
Countries,
subdivided
into 4 groups
Supporting countries have within their sub-groups agreed rotas and take turns. Within some sub-groups of supporting countries,
they have agreed that Board Members should stand down after a year, making way for another representative from another
supporting country.
Oil and gas
“Each subConstituency
shall have the
power to decide
at its own
discretion which
members of that
sub-Constituency
shall be an EITI
Board Member or
an alternate.
They may
formalise the
Companies
Mining
companies
In case there are more candidates for Board seats than there are available Board seats for the subConstituency of oil and gas and the candidates cannot agree amongst them which candidates will be
nominated as full Board members or as alternate Board members, the sub-Constituency shall appoint an
individual, who is not a candidate him/herself, to facilitate an election for the available Board seats. The
individual so appointed shall set forth the election procedures, organise the election (per e-mail) and shall
announce the results from the election to the entire sub-Constituency and shall circulate the formal list with
Board member nominees for the sub-Constituency of oil and gas companies to the wider Constituency and to
the EITI International Secretariat.
The International Council on Mining and Metals (ICMM) agreed to facilitate the selection of the mining and
metals sub-constituency’s board representatives. If there are more nominations than places to be filled,
ICMM will convene a call between the nominees with the aim of reaching consensus on board
representation. If consensus on board representation cannot be reached, ICMM will call an election. An
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The
…is divided
Constituency into…
of…
… which conduct their nominations processes in the following manner:
election
procedure… or
apply an informal
procedure.”
Institutional
investors
Civil society
--
election has not previously been required, but if it were to be, ICMM would convene a ‘hustings’ call of all
participating companies and an election would then follow. ICMM will announce the results from the
election to the entire sub-constituency and shall circulate the formal list with board member nominees for
the sub-constituency of mining and metals companies, the wider constituency and to the EITI secretariat.
In case there are more candidates for the institutional investor board seat than there are available for the
sub-constituency and the candidates cannot agree amongst them which candidates will be nominated as full
board members or as alternate board members, the sub-constituency shall appoint an individual, who is not
a candidate him/herself, to facilitate an election for the available board seats. The individual so appointed
shall set forth the election procedures, organize the election (per e-mail) and shall announce the results from
the election to the entire sub-constituency and shall circulate the formal list with board member nominees
for the sub-constituency of institutional investors to the wider constituency and to the EITI secretariat. Board
candidates must be from an EITI supporting investor organisation.
Publish What You Pay (PWYP) serves as a coordinating body for the nominations process for civil society. As per the governance
structure of PWYP, the Global Council is responsible for developing the criteria as well as overseeing the process which is
executed by a Nominations Committee.
An open call for nominations is made. Any civil society representative can apply. A first round of selection is made, based on a
voting system in relation to criteria. A Selection Panel is agreed. Selected candidates are interviewed by Selection Panel members
and subsequently ranked. A final decision is made by Committee, endorsed by the Global Council. A public report is made that
documents the process and result.
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3 Constituency Coordinators
Questions to consider:
7. Do you think that each Constituency should be encouraged to have a dedicated coordinator?
Should this be a requirement? (This could require changes to the Articles of Association.)
8. Should there also be sub-Constituency contact-points?
9. If so, what process do you think that your (sub)Constituency should use to nominate their
coordinator/contact point?
10. Do Constituency Coordinators need to be EITI Board Members?
11. Do you have any other comments about Constituency Coordinators?
Background
Constituencies are at the core of the EITI’s governance structure. Constituency coordinators can help
ensure that there is appropriate representation on EITI Board Committees and that there are adequate
systems for coordination and communication within the (sub)Constituencies and with their members. It
would also give the Chair, other Constituencies and the Secretariat a point of contact from whom to seek
advice on issues related to that (sub)Constituency.
The 2015 Governance Review generally found “good levels of coordination and communication within each
constituency, as well as between Board members and members of their constituency who are involved in
EITI but who do not sit on the Board”. The report added that “most constituencies hold regular meetings or
teleconferences in order to consult with one another on issues being considered by the Board and in some
cases key committees; these processes are to be commended.” The Review also recommended the
nomination of Constituency coordinators and the Board discussed the issue at its meeting in December
2015. The Board noted that “there [was] merit in the idea of each (sub)Constituency having a nominal
coordinating head/point of contact for general issues” and added that “each (sub)Constituency could select
a Board member amongst themselves – possibly the person who has served longest on the Board and/or
according to the criteria defined by the Constituency.” Having a clearly identified person coordinating
Constituency activities could bring a range of benefits, including facilitate decision-making as this person
could for example meet with the other Constituency coordinators ahead of each Board meeting.
Some Constituencies and sub-Constituencies have in place coordination mechanisms. The civil society
Constituency guidelines provided ahead of the latest Members’ Meeting state that “Publish What You Pay
(PWYP) serves as a coordinating body for the nominations process for civil society”. Likewise, the mining
sub-Constituency guidelines state that “ICMM has agreed to facilitate the selection of the mining and
metals sub-Constituency’s board representatives to serve on the EITI Board”. Implementing countries have
also experimented with regional contact points to facilitate communication within their Constituencies.
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The Global Fund to Fight HIV-AIDS, TB and Malaria requires Constituencies to identify “Constituency Focal
Points” and considers their work “vital to the process of good information sharing and exchange within
Constituencies”, adding that “the importance of this role cannot be emphasized enough”. According to the
Fund’s “Guidelines on Constituency Processes, Constituency focal points should “develop an extensive
network of contacts, including designated focal points, within the Constituency to ensure information
related to the Global Fund is widely distributed; … ensure that all communications from the Global Fund
Board and Secretariat are distributed to all contacts within the Constituency; … be the catalyst and the
repository of Constituency opinions and positions on Global Fund matters…”, among other things.
As discussed above, Constituencies are meant to be broad and inclusive. Without some form of
coordination, it can become difficult for the constituency to operate in a coordinated way and it can be
challenging for EITI to relate to the many different stakeholders that constitute a Constituency in a
meaningful manner. At the same time, individuals or organizations that volunteer to coordinate the work of
the group have processes to ensure that it is seen to be legitimate and representative of the majority.
Institutionalising Constituency coordinators and/or sub-Constituency points of contact can address this
challenge by formalising the practice. What are the downsides? Could it be overkill to require it?
A further question is whether Constituency Coordinators need to sit on the EITI Board. Currently there are
constituency and sub-constituency coordinators that do not sit on the Board. For instance, the ICMM for
companies and PWYP for Civil Society. The Global Fund to Fight HIV-AIDS, TB and Malaria, for example, has
the following guidance for Constituencies: “In many cases the Focal Point is from the Board member’s
country/organization, although in some cases the focal point is a representative of an organization which
assists in managing the Constituency process. Current practice suggests that it is useful if the Focal Point is
close to the Board Member either as part of the same office or based in the same country. In any case, the
main criterion should be access to a reliable communications infrastructure”.
4 Responsibility of Board members towards their constituencies
Questions to consider:
12. Should Constituencies be encouraged to explain in their guidelines how Constituencies are to be
consulted and informed of discussions by the EITI Board that could affect their interests?
13. Are there important country-specific (e.g. Validation decisions) or strategic policy issues (e.g.,
proposed changes to the EITI Standard) or governance issues (e.g., proposed changes to the EITI
Articles of Association) that Board Members should ideally only contribute towards after
Constituency consultations?
14. Should the EITI itself, i.e. the Secretariat, provide greater support to enable Constituency
consultations?
15. Do you have any other comments about Board members’ responsibility towards their
constituencies?
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Background
Under Norwegian law, Board members have a personal responsibility to the EITI Association, meaning that
they have an obligation to adopt – and act upon – their own positions as individuals, irrespective of the
mandate given to them by the stakeholders they represent. At its third Board meeting, in 2007, the EITI
Board agreed that Board Members would be “named individuals that represent their organisations”. It is
not countries, organisations or companies that serve on the Board, but individuals that are Board Members
and it is up to them to find the best way to represent the interests of his or her Constituency.
The 2015 Governance Review contains the following:
“The make-up of the EITI Board is very different to that found in most other organisations and for Board
members it creates a three-way tension of loyalties between their obligations to their sponsoring
organisation (i.e. the individual government, company or civil society group, as the case may be, that
employs them); their broader Constituency; and to the EITI Association as a whole. We make this
observation because a number of the tensions that exist within the EITI have come about because for some
that division of loyalties is not evenly balanced – some feel little loyalty to their Constituency; some feel
that their Constituency demands too much loyalty at the cost of their individual views and obligations;
others feel that decisions are being made that give little consideration to the overall well-being of the EITI;
and some feel that their obligations to the EITI as a whole are synonymous with upholding their
Constituency’s interests since EITI is about achieving balance between three different perspectives.
Those conflicting loyalties will always exist on multi-stakeholder governing bodies and the best way that an
organisation such as EITI can hope to manage them is by regularly reminding Board members of the general
duties of all Board directors everywhere, namely, to:
-
be attentive and diligent – i.e. to read documents and to represent those views in person rather
than via proxies; be attendant – i.e. present at all Board and committee meetings;
be deliberative – i.e. to make decisions based on good information, discussion, and without conflict
of interest; and
hold confidences.
Variations of these rules of conduct or obligations are reasonably standard in most organisations – EITI
reflects them in the induction that is provided at the beginning of a new Board term[1] as well as in the EITI
Association Code of Conduct.[2]”
Consultations are conducted differently by different Constituencies, some do it regularly and on a variety of
issues, others less so. The civil society Constituency, for example, consults extensively and widely including
making active use of mass mailing lists to inform the broader constituency in advance of the subjects that
will be under discussion in Board meetings and of their outcome afterwards. Company sub-Constituencies
often arrange open teleconferences. Representatives from Implementing Countries in Francophone Africa
meet regularly ahead of Board meetings to arrange a common approach; representatives of Region 6
[1]
[2]
https://eiti.org/files/roles-and-responsibilities-eiti-board-members.pdf
https://eiti.org/files/Code_of_Conduct_FINAL_EN.pdf
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implementing countries are consulting regularly via the recently introduced Zoom platform for video
conferencing,
5 Board terms
Questions to consider:
16. Do you think that there should be a term limit for Board Members? If so:
a. Should term limit concern individuals or the entities (country/company/organisation)
that they represent?
g. Should term limit be mandatory) or something that Constituencies decide for
themselves? (This would require changes to the Articles of Association.)
17. Should Board Members be asked to serve full terms? (This could require changes to Articles of
Association if mandatory.)
18. Do you have any other comments about Board Members’ responsibility towards their
constituencies?
Background
According to Article 8.1(i) Board Members and the Chair of the EITI are elected by the Members’ Meeting,
which is regularly held at least every three years (Article 7.3). The Articles of Association state that the term
of the EITI Chair may be renewed once (Article 11.1). Article 9.3 says that “All Board Members retire with
effect from the conclusion of the ordinary EITI Members’ Meeting held subsequent to their nomination, but
shall be eligible for re-nomination at that EITI Members’ Meeting.” Thus, there is currently no limit on the
number of terms that a Board Member or his or her alternate may serve.
The 2015 EITI Governance review recommended that the Board should consider whether they wish to
adopt some form of term limits for Board Members, taking into account the need to strike a balance
between experience and commitment on the one hand, and opening up for new representation on the
Board on the other. Such limits could be mandatory and reflected in the Articles of Association or be
incorporate in the Constituency Guidelines. Limits could either relate to individual or organisations. At the
same time, the Governance review also noted that there was some frustration with the decision by some
sub-Constituencies to regularly rotate their representative on the Board in order to give different members
turns at representation. The Governance review “strongly discouraged” that Board Members serve less
than their full term (i.e., the period between two EITI Conferences, usually 3 years).
The EITI Board considered the recommendation of the Governance Review at its meeting in December
2015 and noted that “The civil society Constituency has already established a two-term limit.” The Board
concluded that “there may be good reason for different decisions within different Constituencies” and
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considered whether the Articles of Association should “directly require that these issues be considered in
the Constituency Guidelines”.
The EITI Governance Committee again considered the issue of term limits ahead of the meeting of the EITI
Board in October 2016. The Committee agreed to suggest to stakeholders through this Consultation “that a
Board member can serve no more than two consecutive terms as Board members” and that in addition
there is either a limit of one term or no limits to the number of terms the same person can serve as an
alternate before and after serving as a Board member”.
6 Participation requirements by Board Members
Questions to consider:
19. Do you think that Constituency Guidelines should set out consequences if Board level attendance
falls below a certain level, and if so, what should they consider?
20. Do you think that Constituency Guidelines should set out consequences if Board Members fail to
actively participate in at least one Board committee, and if so, what should they consider?
21. Should candidates to the Board be required to have their nominating organisation confirm in
writing that they have the resources available to fulfil the responsibilities as a Board Member or
alternate?
22. Do you have any other comments about Board Members’ responsibility towards their
constituencies?
Background
The 2015 Governance Review identified participation by EITI Board Members as an area of concern for the
governance of the EITI. The review recommended a number of ways to address this, including adding new
provisions to the Articles of Association that allow Constituencies to remove and replace a Board Member if
their level of attendance drops below a certain level and recommending that it should be mandatory for
Board Members to sit on at least one committee. The review made particular note of the lack of
participation of implementing countries, not least due to the absence of funding being made available to
fund their participation in Board Meetings.
As a result of the recommendation of the 2015 Governance Review, the Articles of Association was
amended to read “Should a Board member fail to attend three consecutive Board meetings, the Board may,
after consultation with his or her Constituency, require the Constituency to replace the Board member”
(Article 9.5). At its meeting in December 2015 the EITI Board also considered the recommendation that all
Board Members sit on at least one Board Committee, which the review argued would “allow… a better
understanding by all Board members of the business of the organisation as a whole… greater opportunities
to participate in multi-stakeholder deliberations outside of the major Board meetings, [and] increase the
likelihood that committee meetings are quorate and are able to make recommendations to the Board”.
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The Board noted that “given the diversity of the Constituencies, the appropriate and adequate
representation on each Committee might be best decided at the Constituency rather than Board level”.
It is the responsibility of the Board Members and their Alternates to ensure, through confirmation from
their nominating organisation, that they have adequate resources and time to fulfil their functions. Board
Members and their alternates representing civil society organisations from non-OECD receive financial
support from the EITI. A growing number of Board Members and their alternates have indicated to the
Secretariat that they have difficulties in securing funding for participating in Board Meetings. It may
therefore assist possible Board Members and the EITI if from the outset the availability of resources for
Board work is confirmed in writing by their nominating organisation.
It is a significant decision for the EITI Board to require that a Constituency replace a Board Member. One
option is that the Board, through its Chair, writes to the concerned Board Member encouraging him/her to
stand down if she/he fails to attend three consecutive meetings in accordance with Article 9.5 of the
Articles of Association.
Most if not all Board members sit on at least one Board Committee, but some Board Members do not
attend meetings frequently or otherwise participate actively. The Board is interested in stakeholder views
on how the EITI should encourage inactive Board Members to become more active and what sanctions, if
any, are considered reasonable.
To address the challenge of Board Members not being able to participate in Board Meetings due to lack of
funds, it has been suggested that, for example, governments be required to confirm funding before
agreeing a nomination. Constituencies could be encouraged to include in their guidelines provisions stating
that “It is the responsibility of a Board Member and their alternate to ensure that they have the adequate
resource and time to fulfil their functions. Anyone wishing to be a candidate to the Board is required to
obtain from their respective country or nominating organisation a confirmation in writing that adequate
resources will be made available.”
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7 Board vacancies
Questions to consider:
23. Should there be clearer guidelines on the procedures for how Constituencies agree Board
nominations between Members’ Meetings and if so what should they contain?
24. Do you have any other comments about Board vacancies?
Background
In the case of a vacancy, the Constituency has often conducted a more limited consultation process before
agreeing to a nomination as compared to before the Members’ Meetings. In cases where the Board
Member has resigned, it has not always been the case that the Alternate has taken over, but the
Constituencies has simply nominated someone representing the same organisations as was previously
represented. In the case of the Implementing Countries Constituency, the result from the most recent
voting has at times been consulted, with the individual who placed second in the elections ahead of the last
Members’ Meeting being nominated. The question is whether Constituencies should have clearer
guidelines for the process of agreeing nominations between Members’ Meetings and, if so, whether the
EITI should provide recommendations to Constituencies on how this should best be done.
8 Dispute resolution within constituencies
Questions to consider:
25. What, if any, failings can you identify in the existing constituency dispute resolution mechanisms?
How do you think the existing mechanism can be improved?
26. Should the EITI encourage the Constituencies to develop more refined procedures in their
Constituency Guidelines on dispute resolution? What should be key qualities of a dispute resolution
mechanism at the constituency level?
27. Do you have any other comments about dispute resolution within constituencies?
Background
The Articles of Association gives the EITI Board the power to “terminate any Members’ Membership of the
EITI Association if i) the Member… does not comply with [the] Articles of Association; or ii) the Member…
has conducted his/her… affairs in a way considered prejudicial or contrary to the EITI Principles” (Article
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5.5). Article 6 adds that “a resolution by the EITI Board in accordance with Article 5.5 may be appealed by
any Member to the Members’ Meeting for final decision”.
As the governing body of the EITI, it is the Members’ Meeting that has the final word on any disputes. It
seems appropriate that Constituencies in their own guidelines establish some procedures on how internal
Constituency disputes should be resolved.
For other forms of grievances, the EITI has different procedures that stakeholders can make use of
depending on whether the grievance concerns implementation of the EITI Standard, a decision by the EITI
Board, a breach of the Civil Society Protocol or a breach of the EITI Code of Conduct. For example, the EITI
Code of Conduct states:
“EITI Office Holders with a concern related to the interpretation, implementation or potential
violation of this Code of Conduct shall bring such issues to the attention of the immediate EITI
body. Where matters are brought to the attention of the EITI Board, the Board will consider
the circumstances and consider whether action is necessary in accordance with the EITI
Principles, the EITI Standard and the Articles of Association. Anybody who is uncomfortable to
raise any such concerns with the immediate EITI body may bring their concerns to the
attention of the EITI Board through its Governance [and Oversight] Committee and its Chair”.
Grievance mechanisms are explained in further detail on the EITI’s website:
https://eiti.org/voicing-concerns
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