“The DIHR indicates that the general provisions of the Danish Public Administration Act, which regulates impartiality and conflict of interest, are applicable to its members and staff. It further notes that Section 9 of the DIHR By Laws and Board Rules of Procedure provide that members of the Board must notify the Board if there are circumstances which would raise doubts as to their independence and integrity and can provide information.

However, there do not appear to be additional provisions – in legislation, regulation, or another binding administrative guideline – that provide further guidance on other types of activities that constitute a conflict of interest or the process by which a determination would be made about the existence of such a conflict.

The SCA is of the view that avoidance of conflicts of interest protects the reputation, and the real and perceived independence of NHRIs.

The SCA encourages the DIHR to develop further binding guidance with respect to what constitutes a conflict of interest and the process by which a determination would be made about the existence of such a conflict.

The SCA refers to Paris Principle B.2.”