December 20^th, 2020

The Chairman and Members

Grenada Integrity Commission

Office of the Grenada Integrity Commission

P.O. Box 50, Archibald Avenue

St. George’s

Attn:  Lady Anande Trotman-Joseph, Chairman

Dear Madam Chair,

Re Your Letter of November 24^th, 2020

Thank you for your letter of November of 24^th  in response to my letter of June 12^th and follow-up letter of November 7^th.   I am writing to you  in my personal and individual capacity and have taken note of the contents of your letter.

1. Conflict of Interests:
2. Commission Members:  I have noted the information proffered in respect of policy guiding the Commission and its members re “conflict of interests”.
3. Senator:  I have noted the information in respect of the Senator.  To the best of my knowledge, the Senator was  appointed after the 2018 elections.    I am not quite sure when the Senator also became a  citizenship by investment agent.  But I am quite sure that the Senator became a citizenship by investment local agent while serving as a senator. 
   1.  Furthermore, was this Senator also a member of the Board of Directors of the Marketing and National Importing Board, now under your investigation?
4.  Physical Development and Control Authority et al:  Based on the letter, I understand that enquiries are being undertaken and the findings will be shared on camera.

• Integrity Commission and Persons Holding Diplomatic Office:

The letter did not respond to the queries posed in respect of the Commission’s relationship with  Grenada’s Ambassadors.  It advised that the Commission was not responsible for/did not have any say in the appointment of ambassadors.  That is understood.  However, clarification was required in respect of the following:-

• Are all Ambassadors also public officers who need to make declarations just as  other persons holding public office?   Or, are there ambassadors/persons holding diplomatic positions  who are exempt from certain obligations under the Integrity in Public Life regulations? 
• What is the status of ambassadors such as Grenada’s Ambassador to the Russian Federation, H.E. Oleg Firer?  The boundaries in respect of his official role and the public interests vis-à-vis what appears to be full time pursuits of varied private interests  are  uncomfortably opaque.

• Eastern Caribbean Block Chain Association:

I have noted the your comments in respect of this organisation – associated with H.E. Firer – whose website describes it  as a not-for-profit organisation.  I look forward to further  information  from the Commission.

• Commission’s Engagement with Stakeholders:
  • National Anti-Corruption System in Grenada and the Round Table Mechanism:

I have, just by chance, Madam, come across your very interesting presentation titled  National Anti-Corruption  System in Grenada[1].     I note that one of the best practices identified is the Round Table mechanism:-   “A system that was introduced, where our stakeholders can monitor the impact of Anti-Corruption Programmes and Activities aimed at sensitizing persons about  corruption and the structures that they can introduced to monitor the anti-corruption initiatives and its  effectiveness”.   Permit me to enquire who/what constitutes this mechanism?  When does it meet?  What authority does it have, if any?  Is civil society (citizens and/or organisations), outside of the faith based organisations, represented on this Round Table?  Is there a role for civil society?   I look forward to hearing more about how this mechanism works and its impact or to be directed to where I might find that information.

• Corruption/Corrupt Practices/Conflict of Interests:

Madam Chair, your letter thanks me   for “…….committment to bringing to the fore alleged instances of corruption and corrupt practices”.  That is how it is described by you Madam Chair.   Am I to conclude, Madam Chair, that the various concerns that I have brought to the attention of the Commission may be  perceived as corruption/corrupt practices?

Given my own lack of “learnedness” on legal interpretation and appreciative of the need for enquiries by competent authorities, my letter has been very specific in bringing to the attention of the Commission, what I consider situations of “untenable conflict of interest” and the absence of transparency which are not in the best interest of the good governance practices of the country.  I look forward to learning of the findings of the enquiries of the  Commission.

I conclude by reiterating;-

• I am unapologetic in respect of my VERY strong views on the issue of “conflict of interests” and persons holding certain public offices and will be relentless in bringing these instances to the fore, whenever and wherever it comes to my attention. 
• “Conflict of Interests” ABOUNDS and seems to be the NORM at the very HIGHEST levels to the detriment of  governance in Grenada (my opinion).  As “ole people” would say, ”if the priest could play, who is we”!!  What examples are set for those at lower echelons and for our youth and children?

Madame Chair, I take this opportunity to extend to yourself, the members of the Integrity Commission and your team very best wishes for Christmas and the New Year.

Kind regards!

Sandra C.A. Ferguson

[1]https://parlamericas.org/uploads/documents/4OPNGathering_Anande_Trotman_Joseph_ENG.pdf