A conflict of interest declaration form is a standard part of any credible grant assessment process. But most organisations either use a generic form that doesn't capture the nuances relevant to their programme, or ask for a declaration so brief it fails to surface real conflicts.
The declaration form is a process document, not a legal document. Its purpose is to prompt assessors to think carefully about their relationships with applicants — and to create a record of that process. Here's how to design one that works.
A complete declaration form should capture:
Direct financial interests: Does the assessor hold a financial interest in any applicant organisation — shares, loans, property ownership, financial dependence?
Governance and employment relationships: Is the assessor a trustee, board member, staff member, or contractor for any applicant? Have they held any of these roles in the past two years?
Personal relationships: Does the assessor have a close personal or family relationship with a key person at any applicant organisation — a director, senior manager, lead applicant, or primary contact?
Prior advisory relationships: Has the assessor provided paid or significant unpaid advice to any applicant about the project being proposed?
Reputational interests: Would a reasonable person looking at this situation conclude that the assessor's relationship with an applicant might influence — or appear to influence — their assessment?
The last question is the most important and the most frequently omitted. The test for conflict of interest is not just actual bias but perceived bias. A relationship that the assessor is confident wouldn't affect their judgement can still be a conflict if a reasonable observer would question the independence of the process.
Conflict of Interest Declaration — Grant Assessment Panel
Programme name: ___
Round / period: ___
Assessor name: ___
Date: ___
Section 1: Organisation-level declarations
For each applicant organisation in this assessment round, please answer the following:
Do you have, or have you had in the past two years, any of the following relationships with this organisation?
If yes to any of the above, please describe: _____
Section 2: General declaration
I confirm that to the best of my knowledge, I have disclosed all material relationships with applicant organisations in this assessment round. I understand that:
Signature: ___ Date: ___
At panel appointment: A general declaration covering all organisations the assessor has significant relationships with — not just those that applied to this specific round. This allows programme managers to check panel composition before the application list is finalised.
At the start of each round: A specific declaration confirming whether the assessor has any relationships with applicants in the current round. Even assessors who completed a general declaration should complete a round-specific one — relationships change.
When new applications are added mid-round: If additional applications are added after initial declarations have been made, assessors should confirm whether they have relationships with the new applicants.
When an assessor declares a conflict:
Some relationships are clearly material (the assessor is a current board member of the applicant). Some are clearly immaterial (the assessor attended a public event hosted by the applicant two years ago). The middle ground — prior advisory relationships, lapsed personal relationships, indirect financial connections — requires judgement.
When in doubt, err on the side of recusal. The cost of an unnecessary recusal is one less assessor on one application. The cost of an undisclosed conflict coming to light after decisions are announced is significant reputational damage and potentially a review of all affected decisions.
Using the same form for all assessors regardless of role: Staff assessors and external assessors have different potential conflicts. Customise the form accordingly.
Relying on assessors to self-identify conflicts without prompting: Assessors often don't recognise indirect conflicts. The form should ask specific questions about specific relationship types, not just ask "do you have any conflicts?"
Not checking declarations against the applicant list: Declarations that aren't cross-referenced against who actually applied aren't doing useful work. Build time into your process for the programme manager to check each declaration against the applicant list.
Treating declaration as a one-time event: Conflicts can emerge mid-assessment. Make it clear to assessors that they have an ongoing obligation to declare, not just a one-time one at the start of the process.
This article is part of the complete guide: Conflict of Interest in Grant Assessment: A Practical Guide.