An undisclosed conflict of interest is one of the most difficult situations a grants programme can face. It's more serious than a declared conflict — which is a process working as intended — because it raises questions about the integrity of decisions that may have already been made.
How you respond matters as much as the underlying situation. A well-managed response that's transparent, proportionate, and leads to a fair outcome can preserve trust in your programme. A defensive or inadequate response — minimising the conflict, failing to review affected decisions, covering the situation internally — can do lasting damage.
Here's how to approach it.
When a potential undisclosed conflict comes to your attention, resist the impulse to act immediately. Spend time establishing what actually happened.
Questions to answer:
- What is the specific relationship between the assessor and the applicant?
- When did the relationship exist? Is it current or historical?
- Did the assessor know about the relationship at the time of the assessment?
- Could a reasonable person have concluded this relationship was material?
- Did the assessor assess the affected application, and if so, how did their score compare to other assessors?
- Was the application funded, declined, or shortlisted?
Don't assume bad faith at this stage. Many undisclosed conflicts are genuine oversights — the assessor didn't make the connection, or didn't recognise that an indirect relationship was material. Some are more serious.
Not every undisclosed relationship requires the same response. Materiality is the key question: was the relationship significant enough that it could have — or could reasonably appear to have — affected the assessor's judgement?
Likely material:
- Current governance or employment relationship
- Financial interest
- Close family relationship
- Prior direct involvement in preparing the application
Likely immaterial:
- Distant acquaintance through a professional network
- Historical relationship (three or more years ago, no ongoing connection)
- Brief, incidental contact with no ongoing relationship
Requires judgement:
- Former employment relationship (how recently? in what role? what is the ongoing connection?)
- Professional relationship without a governance or employment dimension
- Relationship with a person at the applicant organisation who is not directly involved in the grant
Document your materiality assessment and the rationale.
If the conflict is material and the assessor participated in assessing the affected application, the question is whether the assessment outcome could have been different without their participation.
Consider:
- How significant was the assessor's score relative to other assessors? If their score was close to the panel average, removing it may not change the outcome.
- Was the application on the margin between funded and not funded?
- Was the assessment of this application clearly inconsistent with the assessor's treatment of comparable applications?
If removing the affected score would not change the funding decision, and there's no evidence of deliberate misconduct, a less invasive response may be appropriate — document the situation, acknowledge it to relevant stakeholders, and implement process improvements.
If removing the affected score would or might change the outcome, a more substantive review is required.
Options for managing the affected application, in increasing order of intervention:
1. Remove the assessor's score and recalculate: If other panel members scored the application, recalculate the total without the affected score. This is appropriate when the undisclosed conflict is established but the materiality of the impact is unclear.
2. Seek an additional independent score: Engage an additional assessor to score the affected application without knowledge of the prior scores or the conflict situation. Combine this with the non-affected panel scores.
3. Full re-assessment by a new panel: The most interventionist option, appropriate where the conflict is serious, where the affected application is on the funding boundary, and where there's genuine uncertainty about whether the outcome would have been different.
4. Communicate with the affected applicant: In some circumstances — particularly where a funded application may need to be reviewed, or where an unsuccessful applicant's outcome may change — direct communication with the applicant is appropriate. Take legal advice before doing this.
How you handle the assessor depends on the nature and severity of the situation:
Genuine oversight with no evidence of dishonesty: A direct conversation, acknowledgement of the oversight, documentation for your records, and a clear process for future rounds. The assessor relationship can usually continue.
Apparent negligence (obvious conflict not disclosed): A more formal conversation documenting your concern, a review of their declarations from prior rounds, and a decision about whether to continue the assessor relationship.
Deliberate non-disclosure: This is a serious integrity issue. Document everything, seek legal or governance advice, and in most cases do not continue the relationship. Depending on the circumstances and the severity of the outcome, broader disclosure may be required.
Regardless of what you do, document it. Your record should cover:
- How the conflict came to light
- The nature of the relationship
- Your materiality assessment and the basis for it
- What action you took regarding the affected application
- What action you took regarding the assessor
- Any changes to your process as a result
Report to your governance body. Don't minimise or frame this as resolved before it is. Boards that discover programme managers withheld conflict of interest situations lose confidence in the programme team — the cover-up is always worse than the incident.
The best response to an undisclosed conflict of interest is not having one. The interventions that reduce the risk:
- Specific, prompted declaration questions (not just "do you have any conflicts?")
- Cross-referencing declarations against the applicant list before assessment begins
- A clear process communicated to assessors for declaring conflicts that arise mid-assessment
- An organisational culture where declaring is expected and valued, not treated as a problem
None of these eliminate the risk entirely. But they significantly reduce its frequency and severity.
This article is part of the complete guide: Conflict of Interest in Grant Assessment: A Practical Guide.