COI policies for grantmakers

By Julia_Wise🔸 @ 2023-11-09T19:00 (+59)

Part of this project on reforms in EA. Originally written July 2023

I think grantmaking requires additional steps beyond a standard workplace-based conflict of interest policy. Those policies are designed to address “What if you give a contracting job to your brother’s company?” or “What if you’re dating a coworker?” They are not designed for things like “What if everyone in your social community views you as someone who can hand out money to them and their friends?”

Related: Power dynamics between people in EA

I think grantmaking projects should have a COI policy that applies to full-time, part-time, and volunteer grantmakers and regrantors. It could also be useful for people who are regularly asked their opinion about grant applications or applicants, even if they don’t have a formal role as a grantmaker.  

Things for grantmakers to remember

Power is tricky. Smart, caring people have messed up here before.

Think about what looks unethical from the outside as well as what you judge to be unethical. You might not be a good judge when it comes to your own decisions, and others will make judgements based on what things look like from their perspective.

A written policy doesn’t cover everything. You might notice situations that feel a bit icky to you. I suggest bringing those up with someone at your grantmaking project to get some help figuring out what to do.

Example policies

Several of these are linked from the org websites or from this discussion. Some other organizations have COI policies that are mostly about relationships between their own staff, rather than between grantmakers and grantees.

• EA Funds policy
• ACE policy on COIs by grantmaking committee
• Rethink Priorities policy
• Example from Charity Entrepreneurship’s policy of something to avoid:
  “A Director who is also a decision-maker of a separate organisation who stands to receive a benefit from CE, such as a grant. To an external observer, it could look like the Director used their position as a Director of CE to secure a grant for the other organisation, which otherwise would not have received such a grant.”
• From another grantmaking program: “We ask you to flag conflicts of interest, but they aren’t a knock-down reason that we won’t fund a grant. You can propose funding for friends, coworkers, employees, and even yourself. We will screen these proposals more carefully. . . . You shouldn’t let a potential COI deter you from submitting a promising grant, we just want to know! The main COIs we view as insurmountable are grants to romantic partners.”
• Draft policy for the Long Term Future Fund (with discussion in the comments that may be useful)

Things for grantmaking projects to consider when writing a policy

Often people will know more about projects they’re close enough to have a conflict with, and I can see valid reasons to use that info. There may be ways to consider their input without having them involved in the final decision; for example they could share information/opinions but not participate in any final voting/recommendation on a grant.

Possible elements for a policy to include

What kind of relationships should be disclosed, even if they don’t require recusal? (For example I suggest that being friends or housemates should be disclosed, but doesn’t require recusal.)

What kind of relationships require recusal?

Types of relationships to think about 

• Doing paid or volunteer work for the grantee project
• Board member of the other project
• Housemate / landlord / tenant
• Close friends
• Family member
• Current romantic or sexual partner
• Past romantic or sexual partner
• Your partner or close family member has a COI with the grantee
• People who owe you money, or vice versa
• People who run a project that’s competing with yours
• People you have strong feelings about for some reason (examples: you’ve argued on the internet a lot, they supported you during a time of personal struggle)
• Cases where you feel for some reason it would be awkward to turn the person down

How much info to give about a conflict?

Grantmakers understandably may not want to give details of their personal life as it relates to possible grantees. One option is for grantmakers to say “I have a conflict here, I don’t think I should be involved” and for the grantmaking project to not ask further what the conflict is. 

Another option is to have different levels of COIs: “moderate” like housemates or coworkers, “high” like close family or current romantic partners.

If a grantmaker isn’t sure if a relationship requires recusal, ideally there’s someone at the project who functions like HR, with whom the grantmaker can privately discuss the nature of the relationship.

Before a grant is made

Ideally the conflict of interest policy is public or is otherwise conveyed to potential grantees, so people know what to expect and are more able to recognize if the policy isn’t being followed.

If a grantmaker has an existing relationship (significant enough to require recusal) with someone who applies for a grant from their program, I recommend that the program or the grantmaker should communicate “Someone else at the program will be responsible for deciding about any future grant applications from you.”

After a grant is made

I recommend a policy that grantmakers should not ask out or date anyone they’ve granted to. The exception could be after some period of time has passed, and one or both of the people is in a different role such that the grantmaker-grantee relationship is no longer relevant.

If a COI develops, as above I recommend that the grantmaker or program should communicate: “Someone else at the program will be responsible for deciding about any future grant applications from you.”

The goal here is to avoid incentives for people to join or remain in relationships because of how that might affect their chances at funding.