What counts as a conflict of interest for grant reviewers—and why it matters

Grantmaking decisions carry real weight, often determining which projects or organisations get funded, how much support they receive, and the eventual impact a grantee can create. That means every decision must be defensible. Every review should be clear and impartial.

So, what happens when a conflict of interest arises? How can you handle these with transparency? There’s always the “reasonable person test”: if a reasonable, informed outsider would question a reviewer’s impartiality, it is enough to warrant attention.

But declaring and managing conflicts of interest goes deeper than this. Grantmakers need to communicate clearly to their review panels what constitutes a conflict of interest and create a process that makes it simple to report and handle such conflicts.

In this article, we’ll go over examples of conflicts of interest and how to create a system that fosters integrity and transparency in grantmaking.

Why a conflict of interest process matters in grant review

Conflicts of interest can have myriad consequences in a grant program’s outcomes. And trust, once broken, can be expensive and time-consuming to repair.

Here is why it matters:

Integrity of outcomes: Funded applicants should be selected on merit and/or an outlined rubric, and not any possible relationships.

Public and stakeholder trust: Even the appearance (or hint) of bias erodes credibility. It’s important to remember that donors, beneficiaries and the wider sector are watching.

Legal and compliance exposure: Undisclosed conflicts can create regulatory and reputational risk, especially for government-funded programs.

Fairness to applicants: Significant time and resources go into the application process; applicants deserve an impartial process in return.

The main types of conflict of interest for review panels

Conflicts of interest can come in different formats, and your process of reporting and management should consider all of them. Here is a quick overview.

Financial conflicts

This is when a reviewer has a direct financial stake in an applicant organisation, including:

• Equity, ownership or employment connections.
• Consulting or paid advisory relationships within a defined lookback period
• Receiving compensation, goods or services from an applicant

Personal and relationship-based conflicts

Relationships can create problems in reviewing without bias. These conflicts can include:

• Family members, close friends or romantic partners connected to an applicant
• Close colleagues or former supervisors/supervisees
• Members of the same small professional community where loyalty ties may exist

Institutional or organisational conflicts

This can be when:

• The reviewer is employed by, or affiliated with, an applying organisation
• The reviewer sits on the board or advisory committee of an applicant
• The reviewer’s own organisation competes directly with or would benefit from the outcome

Intellectual or competitive conflicts

This type of conflict could include:

• Prior negative or positive professional history with an applicant or their work
• A stake in an applicant’s work succeeding or failing (e.g. rival research, competing programs)

Perceived conflicts

Even when no actual conflict exists, appearances still matter when it comes to conflicts of interest. It’s important to encourage reviewers to disclose anything that might even look problematic. This helps address any potential problems later on.

How to manage conflicts of interest: Practical steps for grant managers

Before the review

Before the reviewing period even begins, consider the following steps:

• Require your review panel to sign a conflict of interest declaration form before accessing applications.
• Provide clear, written definitions of what constitutes a conflict. (Don’t just assume that reviewers will know.)
• Lay out clear instructions to your reviewers on how they can disclose any conflicts of interest and recuse themselves.

When writing your conflict of interest policy, be sure to include your own definition of various conflicts, your disclosure process, and any consequences of non-disclosure. Then, be sure to review and update the policy regularly, especially as your review panels and program evolve.

During the review

Make it easy and streamlined for your reviewers to disclose conflicts of interest. If it is part of the process, it can be a simple, straightforward step for both your reviewers and/or program managers.

In Good Grants, for example, there are two ways to prevent a reviewer from scoring an application due to potential conflicts of interest.

Abstain: initiated by the reviewer
Recuse: initiated by the grant manager

Reviewers can choose to abstain from scoring a particular application and provide a comment to explain or notate the conflict of interest.

You can also allow grant managers to recuse a reviewer from the management side. A program manager can remove a reviewer from one or more applications using the recusal feature. Reviewers are not notified when they are recused, and recused applications do not appear in their reviewing list.

Adding comments can be helpful in documenting disclosures and recusals as part of your program’s audit trail. 

After the review

Want to take it a step further? Consider asking your reviewers to certify post-review that no undisclosed conflicts arose. Then, keep records in case any decisions are challenged later on.

Building a culture of disclosure

If you build a conflict of interest policy into your grantmaking flow, reviewers will feel safe to declare them. Frame the disclosure process as professional, expected and normal; never an accusation. 

By creating this kind of process, you are protecting your organisation’s grantmaking outcomes, overall mission and grantee impact. 

Learn how Good Grants fosters an equitable review process, with tools for the reporting and management of conflicts of interest, plus more.