1. PURPOSE OF THE POLICY
The Transparency Policy sets out Haklara Destek Programme’s approach and methodology regarding transparency. As a project funded by the European Union Delegation to Türkiye, Haklara Destek Programme also takes into account the principles of the EU Complaints Mechanism and the relevant EU project implementation instructions and regulations.
2. OPENNESS
This policy was established within a framework of openness and transparency, which holds that all information concerning the grant programme and the activities and events carried out under it shall be shared with the public unless a valid exception applies. This framework is grounded in the principles of non-discrimination and equal treatment, in accordance with EU legislation and internationally accepted standards. Haklara Destek Programme attaches importance to being transparent about its decision-making mechanisms, working principles, and methods of implementing EU policies. This transparency reinforces the programme’s credibility and accountability. Transparency also contributes to improving the programme’s efficiency, usefulness, impact, and sustainability.
Haklara Destek Programme defines transparency as the sharing of necessary information, decisions, and documents with applicants, prospective applicants, the European Union Delegation to Türkiye, other project stakeholders, and the general public in a clear, accessible, and timely manner.
3. INSTITUTIONAL FRAMEWORK
Haklara Destek Programme is a sub-grant programme established through a partnership between Hakikat Adalet ve Hafıza Çalışmaları Derneği (Hafıza Merkezi) and Heinrich Böll Stiftung (HBS), with funding from the European Union Delegation to Türkiye. Its aim is to support small-scale rights organisations and grassroots organisations in Türkiye, contributing to the advancement of human rights and participatory democracy.
The programme’s first phase ran from July 2020 to June 2021; its second phase ran from 1 January 2023 to 31 December 2024. The third phase will begin on 1 March 2027 and conclude on 28 February 2029.
At least 55 rights-based organisations legally established in Türkiye will be selected to receive two years of institutional grant support, alongside a programme designed to strengthen their organisational capacity and amplify their impact.
Haklara Destek Programme was designed to contribute to the advancement of human rights and participatory democracy. As set out in Section 2.1 of the Haklara Destek Application Guide, the programme is open to associations, foundations, and non-profit cooperatives (or cooperatives that do not distribute profits to shareholders) with legal personality, that have carried out at least one activity in Türkiye within the past two years contributing to the promotion of human rights or the protection of human rights defenders, in line with the eligibility criteria.
The application period for Haklara Destek Programme opened in July 2026 and ran until 31 August. The evaluation process that followed proceeds in the order described in Section 2.3 of the Haklara Destek Application Guide: administrative check, assessment, and document verification. During the assessment phase, applicants are reviewed and scored on their alignment with the programme, their field of work, impact and contribution, organisational management and development, and budget. Preliminary assessment results are shared with all applicants by email in November 2022. Organisations provisionally selected are required to upload the supporting documents specified in the application guide to the BELLEK Grant Management System within 10 days for eligibility verification. Missing or inconsistent supporting documents may result in rejection. Once documents have been verified, a list of organisations awarded grants is compiled and the contracting phase begins.
The implementation period will run from 1 March 2027 to 28 February 2029. Haklara Destek Programme ensures that the activities of grant-recipient organisations are carried out in accordance with EU policies and legislation, and refers to EU policies and legislation in exceptional circumstances as well. The first article of the Treaty on European Union opens with a reference to the principle of openness. Under Article 15 of the Treaty on the Functioning of the European Union, Union institutions, bodies, offices and agencies shall conduct their work as openly as possible, in order to promote good governance and ensure the participation of civil society. Accordingly, institutions and public administrations in enlargement countries are expected to uphold the principles of transparency and accountability. All institutions are also called upon to ensure transparency in their operations and to include specific provisions on access to information.
4. PUBLICATION OF INFORMATION
In order to uphold and promote the principle of transparency, Haklara Destek Programme shares accurate information about its role, policies, and activities in a timely and regular manner. To this end, a broad set of documents is published throughout the programme. The documents and materials supporting the core principles, alongside this Transparency Policy, are as follows:
- Application Guide and annexes
- Application Form
- Frequently Asked Questions
- Visibility Guide
- Rights-Based Approach Document
- Disclosure and Consent Text on the Processing of Personal Data
In addition to application support videos, Haklara Destek Programme establishes a help desk to allow applying organisations to access support easily by phone throughout the application process. It also organises online Q&A sessions held three times during the application period. The primary tool for disseminating the documents and information referred to above is the Haklara Destek Programme website (www.haklaradestek.org). In keeping with the principles of fair competition, equal opportunity, and transparency, all programme-related communications are conducted through this website.
The final list of organisations selected to benefit from the programme is shared with the public via the website. The final decision on which information is shared with the public, within the limits set by applicable laws and regulations and EU legislation, rests with Haklara Destek Programme.
5. INFORMATION FOR APPLICANTS AND PROSPECTIVE APPLICANTS
Organisations wishing to apply to the programme can access the necessary information through the tools described in Section 4 and via the website. Applicants who register and access the BELLEK Grant Management System, hosted on the Haklara Destek Programme website, are assigned an application tracking number upon completing their application. During the application period, additional information requests beyond those addressed in the Frequently Asked Questions section may be sent to basvuru@haklaradestek.org. New questions from applicants and their answers are compiled and published on the programme website — without identifying the submitting individual or organisation — in time for the day following each Q&A session held during the application period. This ensures that equal access to information is preserved.
6. DISCLOSURE OF INFORMATION
All information and documents produced under Haklara Destek Programme are subject to disclosure unless there is an accepted reason for non-disclosure. All users applying to the programme are asked to give their consent to share their personal information with third parties in electronic environments.
The agreement text at https://haklaradestek.org/hakkimizda/seffaflik-politikasi/ is associated with this policy.
Social media accounts are legally subject to the hosting services of the relevant organisations (Facebook, Twitter, Instagram, YouTube), including all accounts within those services.
7. EXCEPTIONS
While committed to its Transparency Policy, Haklara Destek Programme also has a duty, under EU legislation, to respect privacy in order to protect personal data and comply with national regulations. Accordingly, certain restrictions apply to the sharing of information and documents. In particular, in accordance with EU legislation on the protection of personal data and the laws of the Republic of Türkiye, access to information shall be restricted where sharing such information would compromise “the public interest” or “the protection of the integrity and privacy of the individual.” Information shall not be shared in the following circumstances:
- Where the commercial interests of a natural or legal person are at stake
- Where the information falls within the scope of intellectual property, court proceedings, or legal advice
- Where the information is the subject of inspections, investigations, or audits
- Where the applicant has not given their consent
8. COMPLAINTS PROCEDURE
Applicants and other natural or legal persons who believe they have been adversely affected by Haklara Destek Programme or its actions, or who consider that they have suffered harm as a result of an error or irregularity in the selection process, may submit a complaint to sikayet@haklaradestek.org. Complaints must be submitted within 10 working days of the date on which the complainant confirms that the events on which the claim is based took place. Complaints received within the deadline will be responded to within 15 working days.