Comments
COI policies for grantmakers
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.
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.
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.
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.
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.)
Types of relationships to think about
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.
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.”
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.
I originally thought this was a good reason for recusal but no longer do. I was told that outside EA it is pretty normal for grantmakers to get board seats. If you are going to give a load of money to a project it seems pretty reasonable to have some level of control, as shares would in a business. Likewise a project may want easy access to someone from the grantmaker so they can get future grants.
Not to say this is always good, but I don't think it requires recusal in many cases (it may be the literal reason for the seat), compared to many other examples.
It sounds like you're describing a case where a granting organization intentionally has one of their staff on the board of a project? I agree that's fine, but it's not the only way you could have a board-member related COI. A classic case would be if a charity applies to a fund (for the first time) and it happens to be a board member at the charity works for the fund. Another way this could happen is if a trusted advisor of a fund happened to be on the board of a charity the fund was considering granting to. Personally, I think these should definitely be disclosed, and depending on the nature of the relationship recusal would often be a good idea?