How do you manage conflicts of interest in grant decision-making?

1 Define and communicate policies

The first step to manage conflicts of interest is to have clear and consistent policies and procedures that define what constitutes a conflict of interest, how to disclose it, and how to handle it. These policies should be communicated to all staff, board members, reviewers, consultants, and applicants involved in the grant process. The policies should also specify the consequences of non-compliance and the mechanisms for reporting and resolving disputes.

2 Train and educate staff and stakeholders

The second step is to provide regular training and education to staff and stakeholders on the policies and procedures related to conflicts of interest. Training should cover the types and examples of conflicts of interest, the ethical principles and standards of grant administration, the roles and responsibilities of different parties, and the best practices and tools to prevent, identify, and disclose conflicts of interest. Training should also include case studies, scenarios, and quizzes to test and reinforce learning.

3 Monitor and document conflicts of interest

The third step is to monitor and document conflicts of interest throughout the grant cycle. This involves creating and maintaining records of disclosures, waivers, recusals, and resolutions of conflicts of interest. It also involves conducting periodic audits and reviews of the grant process to ensure compliance with the policies and procedures. Furthermore, it involves reporting and disclosing any actual or potential conflicts of interest to the relevant authorities, such as funders, regulators, or auditors.

4 Mitigate and resolve conflicts of interest

The fourth step in the grant process is to mitigate and resolve conflicts of interest as soon as they arise. This requires applying measures such as recusal, waiver, divestment, reassignment, or termination to eliminate or reduce the impact of the conflict of interest on the grant decision-making. Recusal means that the person or organization with the conflict of interest withdraws from the process or refrains from participating in certain activities or decisions. Waiver involves obtaining permission from the grantor or an independent party to continue involvement in the grant process, subject to certain conditions or limitations. Divestment requires selling or transferring any personal, professional, or financial interests that cause a conflict of interest. Reassignment assigns the person or organization with the conflict of interest to a different role or project that does not involve the grant. Lastly, termination removes them from the grant process or relationship.

5 Review and improve policies and practices

The fifth step is to review and improve policies and practices related to conflicts of interest on a regular basis. This involves soliciting feedback from staff and stakeholders, evaluating the effectiveness and efficiency of the policies and procedures, identifying and addressing any gaps or challenges, and updating and revising the policies and procedures as needed. It also involves sharing and learning from the best practices and lessons learned from other grantors and grantees, and adopting the latest standards and guidelines for grant administration ethics and integrity.

6 Seek and follow expert advice

The sixth and final step is to seek and follow expert advice when in doubt or when facing complex or sensitive conflicts of interest. This involves consulting with legal, ethical, or professional experts who can provide impartial and objective guidance and recommendations on how to handle conflicts of interest. It also involves following the advice and directives of the experts, and documenting and reporting the actions taken and the outcomes achieved.

7 Here’s what else to consider

This is a space to share examples, stories, or insights that don’t fit into any of the previous sections. What else would you like to add?