Information disclosure policy

Through our Information Disclosure Policy, we strive to provide clear guidance on the specific categories of information that Caritas Europa will disclose to various stakeholders.

Additionally, we outline the types of information that we may be unable or unwilling to disclose, accompanied by transparent explanations for such decisions.

Introduction

As Caritas Europa we strive to be a transparent and accountable organisation. We are committed to upholding high professional and ethical standards, in accordance with Caritas Internationalis Management Standards (CIMS), Core Humanitarian Standards (CHS) as well as the applicable national and international legislation.

In terms of transparency and accountability, Caritas Europa believes that relevant information should be accessible and disclosed, subject to the limitations outlined in this policy. It is expected that such transparency will demonstrate who we are in terms of values, mission, vision and structure, the scope of our work, and that resources are being properly managed, used wisely and for the intended purpose. Subsequently, this policy applies to information held by Caritas Europa. It does not apply to information held by Caritas Europa’s member organisations, although our members are encouraged to have similar policies, in accordance with their national legislation and the CI MS).

Caritas Europa is committed to making information available to the public about our:

  • Strategy, programmes, and core activities;
  • Policies and advocacy positions related to our work;
  • Membership composition;
  • Governance and team structure;
  • Financial situation.

Information concerning Caritas Europa staff, volunteers and interns, which is not necessarily all available on the website for the wider public, is accessible through the Caritas Europa manual (our organisational handbook) on our server. In this manual, we also address internal policies, principles and procedures in relation to Caritas Europa management and operations. This is considered restricted information as defined below.

Information concerning our member organisations, which is not available on the website, is shared and available on the extranet “Baobab”, which is managed by Caritas Internationalis. Baobab is accessible to all staff of Caritas members.

Definitions and legal requirements

For the purpose of this policy, “information” means any content in paper, electronic or other medium, concerning a matter relating to Caritas Europa.

Caritas Europa is registered as an international non-profit association (AISBL), in accordance with the civil law of Belgium, and is therefore guided by Belgian law in relation to public information disclosure.

This policy is therefore also subject to the Belgian data protection and privacy legislation. Accordingly, Caritas Europa will not disclose data, information or photographs about individuals where this is prohibited under applicable law or where it is considered restricted information as defined below and in line with the Caritas Europa Privacy Policy available on our website.

In line with the legal requirements according to Belgian law, the following documents and information will be available and regularly updated on the following external online platforms:

  • Our legal statutes are published in the Moniteur Belge: https://www.ejustice.just.fgov.be/tsv/tsvf.htm, search with Caritas Europa registration number 0450.716.537.
    Whenever there are changes in the statutes, changes of administrators (executive board members or legal representatives) and changes of auditors, the changes will be published in the Moniteur Belge.
  • Annual accounts are published at the National Bank of Belgium: https://consult.cbso.nbb.be/consult-enterprise, search with Caritas Europa registration number 0450.716.537 or name “Caritas Europa”.
    The annual accounts of the previous year and the external audit report on the accounts signed by the secretary general and the president will be published before 30 June of each year.
  • The list of the Ultimate Beneficial Owners (UBO), in our case of being an AISBL: the administrators or members of the executive board, treasurer and secretary general are published at the Ministry of Finance: https://finance.belgium.be/en/E-services/register-beneficial-owners.
    The publication is updated every year with the changes that occurred during the year. Consultation is only possible by using secured access with an ID card and a pin code.
  • Our statutes are also published in the “Carrefour Banque Entreprises Belges” (Belgian register of enterprises): https://economie.fgov.be/fr, search with Caritas Europa registration number 0450.716.537.
    Updates are made in line with the publications in Moniteur Belge (see above).
  • To ensure complete transparency of its activities towards the European institutions, Caritas Europa is registered in the EU’s Inter-institutional Transparency Register: https://ec.europa.eu/transparencyregister/public/consultation/displaylobbyist.do?id=6082564924-85&locale=en.
    The information provided in the Transparency Register is kept up to date by the European Commission and updated by Caritas Europa at least once a year.

The relationship of Caritas Europa and its members is regulated by the legal statutes and the internal rules of Caritas Europa, which are available to all members. The members meet at least once a year at the Regional Conference (Caritas Europa’s highest decision-making body). An agenda and all documents related to their rights and duties as members, and all background information needed – to be voted for or not during the Regional Conference – are shared ahead of the Regional Conference with all presidents and directors of the member organisations via e-mail and made available on Baobab.

Public information

Caritas Europa aims continuously to ensure a high quality in public information and documentation. In addition to the legal requirements above, we publish other information relevant to our work on our website https://www.caritas.eu/, including the following information:

This Information Disclosure Policy has a link or correlation with other policies referring to accountability commitments. Caritas Europa’s organisational policies and principles are also available publicly on our website.

They include:

The above-named documents are available in English.

Evaluation and learning

All relevant guidelines, handbooks, lessons learned, learning platforms and evaluations resulting from consultations, joined work or conducted by Caritas staff, consultants or other external parties are shared within the Caritas network through Baobab.

These are internal documents available only to staff working in the global Caritas network. The Caritas Internationalis general secretariat, the Caritas Europa secretariat or Caritas Europa member organisations decide autonomously which documents they disclose to external parties or to the public.

These documents, tools and publications are governed by the provisions detailed below and include cases where part of the content is assessed to potentially put involved parties at risk or to harm the reputation of partner organisations, individuals or other stakeholders. Under such circumstances, sensitive information will be blacked out before publication.

Extracts of key lessons learnt, successes and failures reflected in evaluations will be shared with donors through progress reports.

Principle of subsidiarity and autonomy of members

Caritas Europa members are autonomous and accountable to their own governance structures as well as towards their communities. They also need to respect legal obligations in place in their country.

Members of Caritas Europa are also members of Caritas Internationalis and are responsible for meeting their obligations following this membership of the global confederation.

Caritas Internationalis member organisations and regions, including Caritas Europa, will ensure that the CIMS are applied.

Caritas Europa makes its assessment reports available on Baobab.

In line with CIMS, Caritas Europa encourages its members to adopt their own information disclosure policies:

  • Implementing partners: Caritas Europa encourages its member organisations to apply and implement the Management Standards (CIMS Art. 1.8);
  • Information disclosure policy: Caritas Europa makes information about its programmes and operations available to the public in accordance with an information disclosure policy that aims at transparency (CIMS Art. 4.8).

Transparency and accountability

The CIMS require member organisations to ensure that partners and other stakeholders, including communities involved in the activities, have access to timely, relevant and clear information about the organisation and its activities, as stated in the following articles of the Management Standards:

  • Accounting and reporting, CIMS Art. 3.4;
  • Transparency and accountability, CIMS Art. 4.1;
  • Communication, CIMS Art. 4.2.1;
  • information sharing, CIMS Art. 4.6.

Feedback and complaints

The CIMS additionally promote the possibility for communities, staff, people concerned by the activities and other stakeholders to give feedback or to complain (Art. 1.7). Caritas Europa’s feedback and complaints policy and related information can be found on the website: https://www.caritas.eu/concerns-and-complaints/.

For people and communities to give feedback or complain, it is key that they are aware of what they can expect from the staff of the implementing organisation as well as regarding deliverables from the project (as mentioned in the section on transparency and accountability above). For this reason, implementing organisations are expected to share their organisational commitments expressed in their code of conduct and/or code of ethics.

Stakeholder involvement

The CIMS encourage member organisations to involve communities in all possible levels of planning, implementing, monitoring and evaluation processes.

In terms of programme management (CIMS Art. 3):

Programme design is undertaken with the active involvement of the communities served, is realistic and evidence based and is adapted as far as possible to the needs of different groups (CIMS Art. 3.2.2).

Projects are implemented with the active involvement of the communities served, using sound planning, monitoring of the results and accountability to stakeholders (CIMS Art. 3.2.4).

Project closure is timely, responsive, and accountable to all stakeholders (CIMS Art. 3.2.5).

Programmes address the different needs, opportunities and inequalities faced by women, men, girls, boys and persons with specific vulnerabilities, prioritises those most affected and maximise their participation in project activities (CIMS Art. 3.2.7).

In terms of stakeholder involvement (CIMS Art. 4):

The organisation ensures, through communication by using effective channels and language and with specific attention for women and girls, that affected people and communities know their rights and entitlements, have access to information and are participating in every stage of the project cycle (CIMS Art, 4.1.1).

The organisation actively promotes the engagement of grassroots communities in its work (CIMS Art. 4.4.1).

The organisation engages with civil society organisations and other stakeholders to avoid duplication, to leverage resources, to develop and implement joint policy development and advocacy efforts and to maximise impact (CIMS Art. 4.5.1).

Restricted information

Not all information is public. There are legal, operational and practical considerations that are necessary to preserve Caritas Europa’s interests as well as those of its members, partners and other stakeholders.

We also refer to our and the GDPR legal framework in this respect.

Moreover, the information under the following categories is considered confidential and not available to the public:

  • Information which is likely to endanger the safety or security of any individual, violate his/her rights or invade his/her privacy, e.g. during crisis or when living under suppression;
  • Information which is likely to endanger (the staff of) the organisation or the security of Caritas Europa members and partners or to prejudice the security or proper conduct of any operation or activity;
  • Intellectual property or other information provided to Caritas Europa on condition of confidentiality, Information covered by legal privilege or under negotiation, including disciplinary and investigative information or related to access to internal audit reports;
  • Advocacy, communication and fundraising strategies, which would be compromised if made public before they were implemented, or which would possibly put Caritas Europa’s competitiveness at risk;
  • Information on Caritas Europa internal administration or operating systems, which is available upon request from the secretariat subject to the limitations outlined above.

The Caritas Europa management, in line with the legal requirements, is responsible for making decisions on restrictions to open information. It is responsible for approving and ratifying any decisions in relation to this policy and for supervising the implementation of this policy. The Secretary General is responsible for making decisions on specific information requests from the public when such information is not directly available.

Copyright and disclaimer

All information and material posted on Caritas Europa’s website is subject to Caritas Europa copyright.

Caritas Europa takes no responsibility for the content or information contained on other linked websites, nor does it exert any editorial or other control over those other sites.

No representation is made, or warranty given, express or implied, as to the completeness or accuracy of information made available by Caritas Europa. The requestor shall apply discretion when using the information made available by Caritas Europa. Caritas Europa will not be liable for any direct or indirect loss arising from the use of the information.

Information requests

If certain information is not available on the Caritas Europa website or cannot be found easily, the public can contact the secretariat. Any inaccuracies or incorrect information in our public documents can also be reported to the secretariat. Contact: info@caritas.eu.

All media enquiries should be handled by the secretary general or his/her delegate. Contact: secretary-general@caritas.eu.

Additionally, contact details for all staff can be found on the website.

All requests will be responded to within 30 days.