The document below is a first draft of a COI policy for the Long Term Future Fund. I drafted this a few weeks ago with some people from CEA and the other fund members, but overall am not very attached to anything in this document. I am very curious about ideas other people have about improving the policy, getting feedback about which parts are unclear, as well as getting high-level feedback on whether the whole frame of this policy is even a good idea.
LTFF Conflict of Interest Policy
This document is the first draft of a supplemental conflict of interest (COI) policy for the Long-Term Future Fund (LTFF). It serves as a supplement to the CEA fund-general COI policy, which deals with a narrower class of conflicts of interest, in particular the cases where the fund member has a direct financial or professional relationship to the grantee. This document tries to be more restrictive and cover a larger variety of potential conflicts of interest. We expect to revise this first draft over time in response to feedback from donors and others.
This supplement policy distinguishes between three different types of conflicts of interest:
- Conflicts that must be disclosed to the other fund members
- Conflicts that have to be publicly documented when the fund recommends a grant
- Conflicts that prevent a grant from being made, or force a fund member to recuse themselves from casting a vote on the grant (recusals and the associated COIs are not generally made public)
Due to the nature of the domain in which we are working, we expect to make a significant fraction of our grants to individuals or organizations we have a past relationship with. As such, we decided that relatively few conflicts should prevent a grant from being made, or should cause a fund member to completely recuse themselves. However, partially in order to compensate for that, we aim to be very open with our existing conflicts and err on the side of making all relevant conflicts known when we recommend a grant.
What follows is a list of situations in which a fund member should definitely disclose a conflict of interest, followed by a list of examples that tries to provide a more extensional definition of our conflict of interest policy.
Situations in which fund members should definitely disclose a COI:
- A fund member has an ongoing romantic and/or sexual relationship with a potential grantee, or was in such a relationship that ended less than a year ago
- This is sufficient cause for recusal of a fund member
- A fund member has a close family relationship with a potential grantee
- This is sufficient cause for recusal of a fund member
- A fund member had some substantial past romantic and/or sexual relationship with a potential grantee that ended more than a year ago, or is a metamour of an applicant in an ongoing relationship
- A sensible guideline for "substantial" might be something like “went on more than three dates” or “lasted longer than two weeks”
- This is not sufficient cause for recusal, but should be made public when the fund member decides to not recuse themselves and the grant is made
- A fund member is a room-mate or a house-mate with a potential grantee, or otherwise shares some close living arrangement
- This is not sufficient cause for recusal, but should be made public in cases where the fund member decides to not recuse themselves and the grant is made
- A very close friend or partner of a fund member is employed, receiving funds from, or has some kind of other directly dependent relationship to the potential grantee
- This is not sufficient cause for recusal, but should be made public in cases where the fund member decides to not recuse themselves and the grant is made
Some examples of situations in which a fund member has to disclose a COI, and some situation in which they do not (though they are generally still encouraged to do so, if it seems at all relevant to the decision):
- Not necessary to disclose or recuse: A fund member is friends with a grantee, but does not share a living arrangement and is not in any way romantically involved.
- Sufficient for disclosure but not recusal: A fund member is close friends with a grantee, spending a considerable amount of high-engagement time together (something like, an average of ~4h a month in the last year, 1-on-1 or in small group settings), or having some past or ongoing collaboration on some significant project (significant project being something like a project with at least $10,000 in financial stakes, or more than 50h of time investment)
- Sufficient for disclosure but not recusal: A fund member is evaluating a potential grantee for some unrelated job position or grant
Addendum: Additional factors to take into consideration for COIs
Here are some additional factors that should make a fund member more likely to disclose information about their relationship with the potential grantee. These are not binding, due to their inherent ambiguity, but serve as guidelines for fund members to decide for themselves whether they should disclose something:
- There is a particularly large power imbalance between the grantee and the fund member that has a potential COI, such as the grantee being in a relatively dire financial situation, or being very early on in their career, or the applicant being themselves a potential supporter or donor to a project that the fund member is working on
- The fund member has some history of conflict with the relevant person that might cloud their judgement in a grant-relevant way, which includes extensive interactions on social media and other online communities
- The potential grantee is perceived by the fund member to be part of some group they’ve historically been in conflict with, or that has pursued opposing political goals
- The fund member is a member of the republican party and the applicant is a vocal member of the democratic party.
- The applicant is working at an organization that is in some competition with some project that the fund member is working on, or that they have an interest in
- For-profit example: The fund member is building a forecasting platform, and the applicant is working on a platform that competes for the same user-base
- Non-profit example: An organization that is closely associated with the fund member is competing for donations with an organization that the applicant is working at
- The fund member has shared particularly intense experiences with the applicant, like intensive workshops or retreats (e.g. week-long silent meditation retreat, CFAR workshops), or the consumption of drugs above a threshold common in casual environments.
- The fund member has received a major favor from, or otherwise feels indebted to the applicant. For example, the applicant might have provided critical emotional support at a time of struggle for a fund member, or has in the past given a major donation to an organization the fund member was associated with.
- More generally, if a fund member has strong positive or negative feelings that on-reflection are unrelated to the work of the applicant, or if for some reason or another a fund member expects to find it unusually emotionally difficult to turn down a grant.
This policy seems too lax to me. In particular, I'm fairly surprised at the very narrow range of circumstances in which individual fund members would recuse themselves. It seems fairly obvious to me that being in a close friendship or active collaboration with someone should require recusal and being personal friends with someone should require disclosure.
In general I feel CoI policies should err fairly strongly on the side of caution, whereas this one does the opposite. I'd appreciate some discussion on why this is the case.
Using the information available to you and not excluding a person's judgment in situations where they could reasonably be called 'biased' is the standard practise in places like Y Combinator and OpenPhil. OpenPhil writes about this in the classic post Hits-based Giving. A relevant quote (emphasis in original):
This seems plausibly right to me, though my model is that this should depend a bit on the size and nature of the collaboration.
As a concrete example, my model is that Open Phil has many people who were actively collaborating with projects that eventually grew into CSET, and that that involvement was necessary to make the project feasible, and some of those then went on to work at CSET. Those people were also the most informed about the decisions about the grants they eventually made to CSET, and so I don't expect them to have been recused from the relevant decisions. So I would be hesitant to commit to nobody on the LTFF ever being involved in a project in the same way that a bunch of Open Phil staff were involved in CSET.
My broad model here is that recusal is a pretty bad tool for solving this problem, and that this instead should be solved by the fund members putting more effort into grants that are subject to COIs, and to be more likely to internally veto grants if they seem to be the result of COIs. Obviously that has less external accountability, but is how I expect organizations like GiveWell and Open Phil to manage cases like this. Disclosure feels like the right default in this case, which allows us to be open about how we adjusted our votes and decisions based on the COIs present.
I don't think I understand what this means, written in this very general language. Most places don't have strong COI policies at all, and both GiveWell and OpenPhil have much laxer COI policies than the above, from what I can tell, which seem like two of the most relevant reference points.
Open Phil has also written a bunch about how they no longer disclose most COIs because the cost was quite large, so overall it seems like a bad idea to just blindly err on the side of caution (since one of the most competent organizations in our direct orbit has decided that that strategy was a mistake).
The above COI policy is more restrictive than the policy for any other fund (since its supplementary and in addition to the official CEA COI policy), so it's also not particularly lax in a general sense.
I am pretty uncertain about this case. My current plan is to have a policy of disclosing these things for a while, and then allow donors and other stakeholders to give us feedback on whether they think some of the grants were bad as a result of those conflicts.
Again, CSET is a pretty concrete example here, with many people at Open Phil being close friends with people at CSET. Or many people at GiveWell being friends with people at GiveDirectly or AMF. I don't know their internal COI policies, but I don't expect those GiveWell or Open Phil employees to completely recuse themselves from the decisions related to those organizations.
There is a more general heuristic here, where at this stage I prefer our policies to end up disclosing a lot of information, so that others can be well-informed about the tradeoffs we are making. If you err on the side of recusal, you will just prevent a lot of grants from being made, the opportunity cost of which is really hard to communicate to potential donors and stakeholders, and it's hard for people to get a sense of the tradeoffs. So I prefer starting relatively lax, and then over time figuring out ways in which we can reduce bad incentives while still preserving the value of many of the grants that are very context-heavy.
I wonder why you think recusal is a bad way to address COIs. The downsides seem minimal to me: The other fund managers can still vote in favor of a grant, and the recused fund manager can still provide information about the potential grantee. This will also automatically mean that other fund managers have to invest more time into investigating the grant, which is something you seemed to favor. I'd be keen to hear your thoughts.
In comparison, using internal veto power seems like a more brittle solution that relies more on attention from other fund managers and might not work in all instances.
In comparison, disclosure often seems more complicated to me because it interferes with the privacy of fund managers and potential grantees.
I think Open Phil's situation is substantially different because they are accountable to a very different type of donor, have fewer grant evaluators per grant, and most of their grants fall outside the EA community such that COIs are less common. (That said, I wonder about the COI policy for their EA grants committee.) GiveWell is also in a landscape where COIs are much less likely to arise.
I think there should be a fairly restrictive COI policy for all of the funds, not just for the LTFF.
The usual thing that I've seen happen in the case of recusals is that the recused person can no longer bring their expertise to the table, and de-facto when a fund-member is recused from a grant, without someone else having the expertise to evaluate the grant, it is much less likely for that grant to happen. This means two things:
1. Projects are now punished for establishing relationships with grantmakers and working together with grantmakers
2. Grantmakers are punished for establishing relationships with organizations and projects they are excited about
3. Funds can no longer leverage the expertise of the people with the most relevant context
In general when someone is recused they seem to no longer argue for why a grant is important, and in a hit-based view a lot of the time the people who have positive models for why a grant is important are also most likely to have a social network that is strongly connected to the grant in question.
I don't expect a loosely connected committee like the LTFF or other EA Funds to successfully extract that information from the relevant fund-member, and so a conservative COI policy will reliably fail to make the most valuable grants. Maybe an organization in which people had the time to spend hundreds of hours talking to each other can afford to just have someone with expertise recuse themselves and then try to download their models of why a grant is promising and evaluate it themselves independently, but the LTFF (and I expect other EA Funds) do not have that luxury. I have not seen a group of people navigate this successfully and de-facto I am very confident that a process that relies heavily on recusals will just tend to fail to make grants when the fund-member with the most relevant expertise is excused.
Having fewer grant evaluators per grant is a choice that Open Phil made that the EA Funds can also make, I don't see how that is an external constraint. It is at least partially a result of trusting in the hit-based giving view that generates a lot of my intuitions around recusals. Nothing is stopping the EA Funds from having fewer grant evaluators per grant (and de-facto most grants are only investigated by a single person on a fund team, with the rest just providing basic oversight, which is why recusals are so costly, because frequently only a single fund member even has the requisite skills and expertise necessary to investigate a grant in a reasonable amount of time).
While most grants fall outside of the EA community, many if not most of the grant investigators will still have COIs with the organizations they are evaluating, because that is where they will extend their social network. So the people who work at GiveWell tend to have closer social ties to organizations working in that space (often having been hired from that space), the people working on biorisk will have social ties to the existing pandemic prevention space, etc. I do think that overall Open Phil's work is somewhat less likely to hit on COIs but not that much. I also overall trust Open Phil's judgement a lot more in domains where they are socially embedded in the relevant network, and I think Open Phil also thinks that, and puts a lot of emphasis of understanding the specific social constraints and hierarchies in the fields they are making grants in. Again, a recusal-heavy COI policy would create really bad incentives on grantmakers here, and isolate the fund from many of the most important sources of expertise.
I've also outlined my reasoning quite a bit in other comments, here is one of the ones that goes into a bunch of detail: https://forum.effectivealtruism.org/posts/Hrd73RGuCoHvwpQBC/request-for-feedback-draft-of-a-coi-policy-for-the-long-term?commentId=mjJEK8y4e7WycgosN
I think this comment highlights some of the reasons for why I am hesitant to just err on the side of disclosure for personal friendships.
I'm sympathetic to this consideration, but I think it applies much more strongly to romantic/sexual relationships than friendships.