1. POLICY OBJECTIVE
The Transparency Policy defines the transparency approach and methodology adopted by the Haklara Destek Program. As a project implemented with EU financing, the Haklara Destek Program takes into consideration the EU Complaints Mechanism Principles, as well as the relevant EU project implementation instructions and bylaws.
This policy is set within the framework of openness and transparency as regards the public sharing of all information related to the grant program and all actions and activities connected to the program, excluding valid exceptions. This framework is based on the principles of non-discrimination and equal treatment in line with EU legislation and internationally accepted procedures. Haklara Destek Program is committed to transparency with regards to its decision-making mechanisms, operation principles and the implementation methods of EU policies. This transparency strengthens the reliability and accountability of the program and contributes to the increase of the productivity, efficacy, impact and sustainability of the project.
Haklara Destek Program defines transparency as the intelligible, accessible and timely sharing of necessary information, decisions and documents with applicants, potential applicants, the Delegation of the European Union to Turkey and other project partners, or in other words, with the public in the general sense.
3. INSTITUTIONAL FRAMEWORK
Haklara Destek Program is a sub-grant scheme financed by the Delegation of the European Union to Turkey and managed in partnership by Hafıza Merkezi (HM) and Heinrich Böll Stiftung (HBS). It aims to contribute to the advancement of human rights and participatory democracy by supporting small-scale and grassroots human rights organizations in Turkey.
The first round of the Haklara Destek Program took place between July 2020 and June 2021. The second one will take place between January 1, 2023 and December 31, 2024.
At least 40 organisations based in Turkey will be selected to receive institutional grants and support for institutional development and impact expansion.
Haklara Destek Program has been designed to contribute to the advancement of human rights and democracy. For this purpose, in line with the conformity criteria stated in Section 2.1 of the Application Guide, the program is open to all associations, foundations, and non-profit cooperatives (with a legal entity status) that have implemented at least one activity involving human rights or the protection of human rights defenders in Turkey in the last two years.
The application period for the Haklara Destek Program begins in May 2022 with the circulation of application support videos and ends on June 30, 2022. As outlined in 2.3 of the Application Guide, the assessment period consists of administrative checks, evaluations, and verification of submitted documents. In the evaluation part, the organisations are given a score based on their works’ relevance to the program, their focus area, impact and contribution, their organisational management and development, as well as their budget. In November 2022, the applicants receive an email with the initial evaluation results. Next, conditionally accepted organisations are requested to upload supporting documents listed in the application guide for verification to the BELLEK Grant Management System within 10 days after receiving the email. Missing documents or inconsistencies in the information provided in the supporting documents can result in the rejection of the application. Following that, a final list of grant-receiving organisations is created, and contract procedures begin.
The implementation period runs from January 1, 2023 to December 31, 2024. Haklara Destek Program ensures that the activities of CSOs receiving grant support are realized within the framework of respect to EU policies and laws, and in cases of exception, takes EU policies and laws as reference. The first article of the Treaty of the European Union begins with a reference to the principle of openness. According to Article 15 of the Treaty on the Functioning of the European Union, the Union’s institutions, bodies, offices and agencies shall conduct their work as openly as possible in order to promote good governance and ensure the participation of civil society. Accordingly, in enlargement countries, public administration and institutions are expected to attach importance to the principles of transparency and accountability. All institutions are also expected to provide transparency in their operations and include specific provisions regarding access to information.
4. PUBLICATION OF INFORMATION
In order to support and encourage the transparency principle, Haklara Destek Program shares, in a timely and regular manner, accurate information about its policies and work. For this purpose, a broad set of documents is published during the program. Along with the Transparency Policy, the following tools support the fundamental principles:
- Application Guideline and Annexes
- Application Form
- Application Support Videos
- Frequently Asked Questions
- Visibility Guideline
- Document for Rights-Based Organizations
- Clarification and Consent Text regarding the Processing of Personal Data
In addition to the application support videos, Haklara Destek Program also offers help through a support desk, which is accessible to the applicants by phone during the application period. Additionally, there are three question and answer sessions held during the same period. The main tool used for the dissemination of these documents and information is the Haklara Destek Program website (www.haklaradestek.org). All information related to the program is provided via this website in accordance with the principles of fair competition, equal opportunity and transparency.
Names of the CSOs that have earned the right to benefit from the program are shared with the public via the website. The final decision regarding the information to be shared with the public within the boundaries set by prevailing laws and regulations and the EU legislation belongs to the Haklara Destek Program.
5. INFORMATION FOR APPLICANTS OR POTENTIAL APPLICANTS
Organisations interested in applying to the program can access the necessary information on the website using the tools referred to in the fourth section. Applicants registered on the BELLEK Grant Management System found on the Haklara Destek website are given an application tracking number after completing their applications. Any additional questions, which are not already answered by the Frequently Asked Questions, can be sent to the e-mail address firstname.lastname@example.org during the application period. New questions from applicants and the corresponding answers are published on the program’s website the day after the Q&A sessions, without indicating the person/organisation that posed the question. This way, the right to equal access to information is exercised.
6. DISCLOSURE OF INFORMATION
All information and documents produced within the scope of Haklara Destek Program are subject to disclosure so long as there are no acceptable grounds that require them not to be disclosed. All users applying to the program are asked to give their consent for their personal information to be shared with third parties in an electronic environment.
The contract document found on https://www.haklaradestek.org/tr/veri-ve-seffaflik-politikasi is related to this policy.
Social media handles are legally dependent on the hosting services of relevant companies (Facebook, Twitter, Instagram, YouTube) including all accounts that are part of these services.
Haklara Destek Program adheres to its Transparency Policy and is also obliged to respect, in accordance with EU legislation, the right to privacy in order to protect personal data and observe the national code. For this purpose, there are a number of limitations related to the sharing of information/documents. Most particularly, EU legislation on the protection of personal data requires that access to such information is blocked if and when the sharing of information endangers the “public good” and the “protection of the integrity and privacy of the individual”. Information is not shared under the circumstances listed below:
- If commercial interests of private or legal persons are in question
- If said information is within the scope of intellectual property, court procedure documents or legal advice
- If the information is subject to inspection, investigation and/or audits
- If the applicant has not given consent
8. CONDITIONS FOR FILING COMPLAINTS
Applicants or other private/legal persons who believe they have been negatively affected by the Haklara Destek Program and its actions, or who believe they have suffered damages due to a mistake or irregularity during the selection process may email a complaint to: email@example.com. Complaints must be sent within 10 working days after the date that the events the claims are based on are confirmed by the complainant to have taken place. Complaints received within the designated period are responded to within 15 working days.