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Independence and conflict-of-interest policy

We work for companies bidding in public tenders and, on separate mandates, for contracting authorities. To make sure there is never a conflict of interest:

  • every request is checked against our independence register before we open any document;
  • we never act for a bidder in a procedure we prepared or evaluated for the authority, and never for two competing bidders on the same lot;
  • the two practices use separate teams and separate document spaces;
  • we sign a confidentiality agreement before any documents are exchanged.

Our rules

  1. Screening at intake. Before we read a tender file, we check whether we have prepared, advised on or evaluated that procedure for the contracting authority, and whether we act for another bidder in it.
  2. No double role. We never take a bidder mandate on a project where we had any role for the authority: preparation, evaluation or co-opted expert. If we cannot act, we say so without giving details.
  3. Exclusivity. Once you accept our Go recommendation, we do not prepare or check a competing bid in the same procedure or lot.
  4. Disclosure. At the Go/No-Go stage we tell you in writing about any mandate we had for the same contracting authority in the previous 24 months, and any relationship with other bidders or with partners we introduce. You may then withdraw at no cost.
  5. Separate files. Authority-side and bidder-side mandates are kept in separate files with separate access rights.
  6. Co-opted experts. Team members appointed as co-opted experts for an authority sign the impartiality declarations the law requires, and that procedure is closed to bidder-side work.
  7. No influence. Our fees pay for documented work. We do not offer, and no fee of ours pays for, access to or influence over contracting authorities, evaluation committees, the CNSC or EU bodies. We communicate with authorities only through the official channels of the procedure, in writing, on your behalf and with your approval.
  8. Integrity. We do not offer, promise or accept undue advantages, make facilitation payments, or give gifts or hospitality to public officials. We cooperate with clients' anti-bribery programmes (UK Bribery Act, US FCPA and similar): questionnaires, anti-corruption clauses and reasonable audit rights. On request, the basis of our fee can be disclosed to the contracting authority.
  9. Know your client and sanctions. Before an international mandate we verify the client, its beneficial owners and its representatives, and screen them against EU sanctions lists. We decline mandates that would breach EU restrictive measures.
  10. No commissions. We take no commissions from banks, insurers or other suppliers we recommend, and no fee from partners we introduce. Referral fees are paid only to professionals under a written agreement, never to anyone in, or able to influence, a contracting authority.

Raising a concern

Concerns about a possible conflict can be sent to contact@consultantseap.ro and are reviewed by the Managing Partner, without retaliation.

https://consultantseap.ro/about/independence-policy/