Republic of The Gambia · Personnel Management OfficeOfficial Reference · Revised 2013
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Financial Disclosure & Conflicts of Interest

Your obligation to disclose investments, shareholdings, and private interests — the rules on pecuniary embarrassment, the Secretary General's power to require divestment, and how undisclosed conflicts constitute Gross Misconduct.

General Orders

GO 03114 requires every Public Officer to disclose to the Secretary General the particulars of any investments or shareholdings they hold in any public or private company operating in The Gambia, and any other direct or indirect interests. The Secretary General may direct the officer to divest if a conflict with official duties exists. GO 03115 goes further — no officer may acquire investments or interests without the Secretary General's expressed permission. GO 03107–03109 address pecuniary embarrassment (serious debt): the Registrar of the Supreme Court, Clerks of Subordinate Courts, and the Commissioner of Stamp Duties must report any officer who becomes a judgement debtor or acknowledges a written debt. An officer who is in serious pecuniary embarrassment is liable to disciplinary proceedings (GO 03109). GO 03110 covers inventions by Public Officers — the regulations are contained in Appendix A of the General Orders. GO 03108 requires officers to whom the Junior Public Officers Relief Act applies to take advantage of the Act's provisions in any legal action against them.

Code of Conduct

Section 3 of the Code defines unethical conduct to include conflict of interest, influence peddling, and seeking personal benefits through one's official position. Section 4.5.2 prohibits using or disclosing official information for personal gain. Section 4.4.5 forbids engaging in any transaction or action that conflicts with official duties. Most critically, Section 6.1.11 classifies as Gross Misconduct the 'failure to disclose private interest in a situation where an employee is called upon to deal with any matter or issue in which he/she has a personal interest.' This is one of the most serious offences — it carries penalties up to dismissal. The practical implication is clear: if you have any financial interest in a company, contract, or transaction that comes across your desk, you must declare it immediately and recuse yourself.