Ministers are expected to devote appropriate time to official business, both as members of the executive and as members of the Legislative Assembly. Holding public office is therefore regarded as a full-time occupation.

Accordingly, accepting additional payment of any nature whatsoever always risks exposing a Minister or official to allegations of bribery, corruption, or conflicts of interest. Apart from being bad government, there is a risk of criminal prosecution. This is particularly the case if a payment is, directly or indirectly, for doing anything that could be regarded as part of a person’s official responsibility. Accepting significant gifts of any sort, including customary gifts, requires good judgment and should be discussed with the Prime Minister, and recorded and may be subject to retention by the State.

For the same reasons, Ministers must ensure that no actual or reasonably perceived conflict exists (or appears to exist) between their public duty and their private interests. Private interests that could give rise to conflicts could include, for example, a Minister’s business interests, a Minister’s family’s interests, association with non-public bodies, receipt of gifts or fees. Appearances can be as important as reality in conflict of interest issues and must be considered in establishing acceptable behavior.

The Integrity Commission maintains a Register of Ministers’ assets and requires Ministers to declare any pecuniary interests, such as shareholding in a private company they control or significant assets they own or control.

If a conflict of interest does arise in the course of Cabinet business, the following possible measures should be considered:

1. a Minister must declare the conflict, but if it is not serious may still receive information and participate in a decision; or
2. if the issue is more serious, a Minister must declare a conflict, and withdraw from receiving any information or participating in a decision, including discussing the matter with those who will be involved in the decision making; or
3. responsibility for a decision or proposal may be transferred to another Minister; or
4. the Minister may be required to divest himself/herself of the interest that causes the conflict.

Which course of action is appropriate will depend on the particular circumstances, including the nature of the interest involved and the nature of the decision. Thus, a Minister with a sick child is not likely to be perceived as having a conflict of interest in arguing for better health care services in general. But a Minister with a sick child seeking the specific allocation of funds to allow that child to receive an operation would obviously have a conflict of interest. It is not possible to cover all circumstances with examples; broad principles must guide decision-making here. Ultimately, ethical conduct requires consent, acceptance of the issues, and self-enforcement. Also, the law (including the criminal law) stands behind these principles.

In practical terms, Ministers should ensure that any possible conflict of interest is promptly addressed. The Secretary to Cabinet should be kept informed and the Prime Minister advised. If in doubt about the appropriate course of action, Ministers should consult the Prime Minister or the Secretary to Cabinet. Specific procedures regarding a conflict of interest that arises during a Cabinet meeting are described in section 8.4.

There is a somewhat grey boundary between conflicts of interest and corruption. The association between the two means that great care must be taken by Ministers and officials to deal openly with any conflicts of interest.

Cabinet members must comply with the Integrity in Public Life Act (No. 14 of 2007) as amended by Act No.2 of 2008 (Laws of Grenada, vol. 8 cap 150A).

Ministers are also expected to comply with the Ministerial Code, a copy of which is available from the Cabinet Office.