Make Conflict of Interest Policies Public

By Jeff Kaufman 🔸 @ 2023-02-09T19:33 (+175)

This is a crosspost, probably from LessWrong. Try viewing it there.

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Alex Catalán Flores @ 2023-02-10T13:00 (+36)

Thank you Jeff for the post. I’m Alex, Director of Operations at Charity Entrepreneurship. We have a COI policy in our staff handbook, but you're right to say that our COI policy isn't public at the moment, so thank you for the nudge. Recent events made us think that we could take this opportunity to review our policy and potentially strengthen it even more, particularly by comparing it to others’ policies in this post. We will take a look and can commit to publishing it on our website before the end of the month. 

Ofer @ 2023-03-03T20:36 (+15)

Hi there!

Has Charity Entrepreneurship published its CoI policy? (I didn't find it on CE's website.)

Alex Catalán Flores @ 2023-03-10T01:02 (+27)

Hi there. As promised, here is CE's Conflicts of Interest policy. We're still waiting for a couple of pieces of advice to come through so the text will likely change and we'll post an updated version. In saying that, there likely won't be wholesale changes.  

ElliotJDavies @ 2023-03-18T12:32 (+7)

CE does not permit Executive Directors initiating a romantic and/or sexual relationship
involving any member of Staff or the Board.

I'm curious what "does not permit" means here, since below this is written fairly modest steps. 

I.e. I am aware Joey (executive director) has dated several members of staff (and still does at point of writing). Do I understand correctly Joey was not permitted to do so, but since presumably he has followed the steps described in the COI, he is permitted to continue?  

To be clear, I am new to COI's so this might be normal, plus I can see COI are not designed as a guide for good workspace culture, but to specifically mitigate a certain form of mismanagement (i.e. what would colloquially be called "corruption"). 

Somewhat related question, do you expect any individual board members have COI in that all are previous founders of CE incubated charities. I am not sure I can point to any direct harms from this, but it does pattern match onto a Revolving Door. The Effective Altruism space is large, so it does seem suboptimal to have only board members that were previously in a subordinate role to the directors of CE. 

Probably not all of my thoughts here are related to COI, but more towards unhealthy  culture around CE and the way it operates. 

Alex Catalán Flores @ 2023-03-09T12:56 (+12)

Hi Ofer, apologies for the delay. We're doing one final round of review and will be publishing it very soon. I will send you a link as soon as it's published. 

Peter Wildeford @ 2023-02-09T22:45 (+24)

Hey, thanks for the suggestion. To save interested people from having to email us, here are links to our conflict of interest policies. We have two: one for our board and one for staff. These are probably pretty standard documents and I would think they do not differ much between organizations (except at grantmaking foundations, where I imagine they are more complicated). I expect the real value comes from really thoughtfully detecting and enforcing conflicts of interest, as opposed to having a written policy that is not well understood or enforced.

Jeff Kaufman @ 2023-02-09T22:51 (+2)

Thanks; requested access to both!

I do think you're right that they're often pretty boring and the important stuff is in organizational practice. In this case, though, I'm especially interested in what sort of things the policies require employees to disclose (internally), which I think probably does (or at least should) vary meaningfully?

Peter Wildeford @ 2023-02-09T22:59 (+9)

Sorry I didn't realize they were restricted. I've made both documents publicly viewable.

Jeff Kaufman @ 2023-02-09T23:06 (+6)

Thanks! I appreciate the speedy responses, though they aren't necessary!

After I've been able to look at ones for a bunch of organizations I think I'll probably do some sort of comparison.

Some things that jumped out to me on skimming these:

  • The board member one seems to only be concerned with financial conflicts of interest, but interpersonal ones also seem like they could be an issue?

  • The employee one maybe covers interpersonal stuff, but not very explicitly. For example, it's not obvious to me under which circumstances two RP employees would need to disclose that they've begun dating.

Peter Wildeford @ 2023-02-09T23:09 (+7)

We have a separate "Personal Relationship Policy" that governs disclosure around dating. The summary is that if an employee has a personal relationship with another RP employee or external stakeholder (e.g., at an EA grantmaking organization) who has perceived or real authority / influence / power to affect RP or its employees, they must disclose such a relationship.

Jeff Kaufman @ 2023-02-10T01:46 (+14)

Is there any chance you might be up for posting that policy as well? I'm interested in understanding how different organizations have decided to handle these.

Would nepotism be handled by one of these, or would that be another policy?

Aaron Gertler @ 2024-04-28T02:49 (+10)

Open Philanthropy has published a summary of the conflict of interest of policy we use. (Adding it as another example despite the age of this thread, since I expect people may still reference the thread in the future to find examples of COI policies.)

Alex Catalán Flores @ 2023-03-10T01:03 (+10)

Hi Jeff, here is CE's Conflicts of Interest policy. We're still waiting for a couple of pieces of advice to come through so the text will likely change and we'll post an updated version. In saying that, there likely won't be wholesale changes. 

Jeff Kaufman @ 2023-03-10T03:42 (+2)

Thanks!

Nathan Young @ 2023-02-10T01:43 (+7)

And they should all be put on a wiki page called "conflict of interest policies"

Nathan Young @ 2023-02-10T12:57 (+5)

What do you lot hate about this? Seems like a reasonable place to put them. And much more credible to be able to say "all our orgs policies are here"

Jason @ 2023-02-10T17:07 (+7)

I'll go even further: policies of potential public interest should be public unless there is an articulate reason to the contrary.

Nathan Young @ 2023-02-10T17:09 (+6)

Ehhh, I can see an issue with everything being transparent. I used to work in the Civil Service and trust me,  the Freedom Of Information act causes a huge amount of busywork. 

That said there does seem to be the general and harmful opinon that EA orgs don't have conflict of interest policies, but they do so sharing them seems good.

Jason @ 2023-02-10T17:13 (+6)

I have a civil-service background as well -- full FOIA would be unreasonable, but "post your policies once every few years unless there are reasons not to post certain portions" isn't a heavy ask.

NickLaing @ 2023-02-10T16:00 (+3)

I agree Nathan, I don't understand the downside. If it's public, it's public so why not just make it more easily accessible?

Jeff Kaufman @ 2023-04-02T11:32 (+3)

GiveWell has now published their Workplace personal relationships policy and Workplace personal relationships guidance, linked from here.