Conflict of interest (COI) management is not optional in grant assessment — it is a core probity requirement. For government funders and Crown entities, inadequate COI management creates legal and reputational risk. For charitable foundations, it creates governance risk and erodes public trust. And for any funder subject to external audit or OIA requests, the COI record will be among the first things scrutinised.
Despite this, COI management is one of the most commonly poorly designed elements of a grants process. The issues are usually not about intent — funders understand that conflicts must be declared — but about process design and documentation.
A conflict of interest in grant assessment exists when an assessor has a personal, financial, professional, or other relationship with an applicant that could — or could appear to — compromise their objectivity in assessing that application.
The critical point is "could appear to." A conflict does not need to be actual to be problematic. The appearance of bias — if an assessor has a connection to a successful applicant that was not disclosed — can undermine the legitimacy of the entire round even if the assessor's judgement was in fact unaffected.
Common types of COI in grant assessment:
- Personal relationships (family member, close friend, partner)
- Professional relationships (current or recent employer, contractor, colleague)
- Financial relationships (shareholder, creditor, financial beneficiary)
- Organisational relationships (board member, volunteer, significant donor)
- Competitive relationships (assessor's own organisation is an applicant or competitor to an applicant)
Less obvious but still significant:
- An assessor who has publicly advocated for a particular applicant or project
- An assessor with strong prior expressed views about an applicant's work
- An assessor whose organisation might indirectly benefit from a particular grant being funded or declined
Generic COI declarations. Asking assessors to sign a blanket declaration ("I confirm I have no conflicts of interest with any applicant") does not work in practice. Assessors cannot reliably identify conflicts against a full applicant list without reviewing each applicant individually. A generic declaration provides legal cover but not actual COI management.
COI collected once at the start of the round. A single declaration at the beginning of the assessment process misses conflicts that emerge during the process — including cases where an assessor knows a new applicant they hadn't previously encountered on the list.
No per-application COI process. The most robust COI process requires assessors to confirm, for each application they are assigned, whether they have any conflict with that specific applicant. This catches conflicts that a general list review misses.
No record of how declared conflicts were managed. A COI declaration is only the first step. The funder's response — whether the assessor was excluded, whether a senior decision-maker reviewed the potential conflict, whether the conflict was judged immaterial — should also be documented. Without this, the declaration is evidence that COI was identified but not that it was managed.
COI records held in email. When COI declarations are collected via email, they are distributed across inboxes rather than consolidated in a retrievable record. When an auditor asks for the COI documentation for a round, reconstructing it from email threads is slow, incomplete, and error-prone.
COI managed informally by the panel chair. In some organisations, the panel chair is expected to manage COI by personal knowledge of relationships between assessors and applicants. This approach fails when the chair is not aware of all relevant connections, and it produces no documentary record.
Per-application declaration. Each assessor, before viewing the full details of an application, is asked to declare whether they have any conflict of interest with that applicant. This can be structured as a simple yes/no question with a free-text field for details.
Clear guidance on what to declare. Assessors need specific guidance on what types of relationships constitute a conflict — not just "any personal connection." The more specific the guidance, the more reliable the declarations.
Documented funder response. For every declared conflict, the funder's response should be recorded: excluded from assessing this application, conflict deemed immaterial (with reasoning), senior review obtained. This documentation is as important as the declaration itself.
Exclusion enforcement. For significant conflicts, the assessor should be excluded from viewing and scoring the application. This exclusion should be enforced by the system, not by an honour system.
Comprehensive COI record. At the conclusion of a round, a complete COI record should be producible — every assessor, every application, every declaration (including nil declarations), every management decision. This record should be held in the grants management system, not in email.
Regular reinforcement. For organisations with standing advisory committees or recurring panels, COI training and refresh should be part of the committee's regular governance, not just a one-time exercise.
A grants management system that treats COI as an afterthought — a PDF form that assessors email back — cannot support a robust COI process. The system should:
Present applications to assessors one at a time with a per-application COI prompt. Before an assessor can access the assessment form for an application, they should be required to confirm their COI status for that applicant.
Log all declarations with timestamps. Every declaration — including nil declarations — should be recorded in the system with the timestamp and the assessor's identity.
Enforce exclusion for declared conflicts. When an assessor declares a conflict, the system should remove access to that application for that assessor. This is not optional — manual exclusion management introduces risk.
Record the funder's response to declared conflicts. The system should allow a programme administrator to record how each declared conflict was managed.
Produce a complete COI report for any round. A programme administrator should be able to generate a full COI record for a round at any time — a matrix of assessors, applications, and declaration status.
For government funders, COI management is directly relevant to probity obligations. A Ministerial inquiry, an OIA request, or an external audit may ask for the COI records of a round. The question is not whether conflicts were declared but whether the process was robust and the documentation is complete.
"Our assessors are professionals and we trust them" is not an adequate response. The accountability standard requires a documented, structured process — not reliance on individual integrity.
Purpose-built grants management platforms build COI management into the assessment workflow by design. Funders running their assessment process through email and spreadsheets typically cannot meet the same documentation standard without significant manual effort.
For funders reviewing their assessment process, the government grants management solution page explains how Tahua handles COI and probity requirements. To see the COI workflow in action.
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