Managing Conflict of Interest in Grant Reviews

Conflicts of interest are one of the most persistent governance risks in grantmaking. They arise whenever a decision-maker's personal connections, loyalties or financial interests could — or could reasonably be perceived to — influence a funding decision. Left unmanaged, they erode the credibility of the entire process: applicants lose trust, boards face regulatory scrutiny, and public confidence in charitable funding declines.

The Charity Commission's guidance on conflicts of interest (CC29) is unambiguous: all trustees have a legal duty to act only in the best interests of their charity, and managing conflicts is not optional. Poor management of conflicts of interest is, year on year, one of the most common themes arising from the Commission's statutory inquiries, according to analysis by VWV Solicitors of inquiry reports published in 2025. In its 2024-25 annual report, the Commission reported concluding 4,375 regulatory concern cases during the year — an 18% increase on the previous year — with governance failures, including conflicts, remaining among the most frequently reported categories of concern (Charity Commission Annual Report 2024-25).

The good news is that most conflicts are manageable. What matters is having clear policies, consistent processes and — increasingly — digital systems that enforce the rules automatically. This guide covers how to build that framework, whether you are a funder running panel reviews or a charity managing internal grant decisions.

What counts as a conflict of interest in grantmaking?

The Charity Commission defines a conflict of interest as any situation in which a trustee's personal interests or loyalties could, or could be seen to, prevent them from making a decision only in the best interests of the charity. CC29 distinguishes two main types (Charity Commission CC29):

Financial conflicts arise where a trustee, staff member, panel member or someone connected to them could receive a measurable benefit — financial or otherwise — from a grant decision. Examples include a reviewer whose organisation is applying for the same fund, or a panel member who holds a consultancy contract with an applicant.

Loyalty conflicts occur where a person's duty or allegiance to another organisation or individual could influence their judgement, even if they stand to gain nothing personally. A trustee who also sits on the board of an applicant charity is a classic example. So is a panel member whose close friend is the chief executive of an applying organisation.

In practice, grantmaking conflicts often fall into recognisable patterns:

• A reviewer is named as a participant or partner in the proposal under consideration
• A panel member is from the same organisation as the applicant
• There is a close personal or professional relationship between the reviewer and anyone named in the application
• A reviewer has previously funded, or been funded by, the applicant
• Competitive tension exists between the reviewer's own organisation and the applicant

UKRI, which manages billions in research funding, uses a similarly structured classification in its peer review policies, requiring panel members to declare conflicts and withdraw from discussions where any of these categories apply (UKRI Conflict of Interest Guidance).

The three-step process: identify, manage, record

The Charity Commission's CC29 guidance sets out a three-step approach that applies to all charities, including those making grants:

Step 1: Identify. Trustees and panel members must recognise when a conflict exists — or could reasonably be perceived to exist. This means maintaining a register of interests and requiring proactive declarations before any grant round begins. Share the list of applicant organisations with all reviewers before assigning applications, and ask each reviewer to flag connections.

Step 2: Manage. Once identified, the conflict must be handled appropriately. The most common approach is recusal: the conflicted person withdraws from the discussion and decision on the relevant application. In some cases — particularly where the conflict is minor or the person's expertise is genuinely needed — it may be sufficient for the conflict to be declared openly and for the person to remain in the room but abstain from scoring. The key test is whether a reasonable, well-informed observer would consider the arrangement fair.

Step 3: Record. Every conflict, every declaration and every management action must be documented. Record who declared what, when they left the room (or abstained), who was present for the decision, and the rationale for how the conflict was handled. These records form part of the audit trail and may be examined by regulators, auditors or applicants who challenge a decision.

This three-step approach is not merely best practice — it reflects the legal duties of charity trustees under the Charities Act 2011 and equivalent Scottish legislation (OSCR).

Why conflicts matter more than funders think

It is tempting to treat conflict-of-interest management as a box-ticking exercise, but the consequences of getting it wrong are serious. Analysis of Charity Commission inquiry reports in 2025 identified conflicts of interest as one of the top three governance issues leading to formal regulatory action, alongside financial controls and non-compliance with governing documents (VWV Solicitors, 2025).

Specific problems identified in recent Commission cases include:

• Conflicts not declared promptly or fully, including those involving connected persons
• Conflicted trustees participating in discussions or influencing outcomes informally outside meetings
• Decisions made without a valid quorum once conflicted trustees are excluded
• Unauthorised trustee benefits or related party transactions, including in grantmaking, without proper authority from the governing document

In its 2024-25 whistleblowing report, the Commission disclosed that it received 546 whistleblowing disclosures, of which 25 specifically concerned conflicts of interest (Charity Commission Whistleblowing Report 2024-25). With nearly one million people serving as charity trustees across the UK, and over 170,000 registered charities in England and Wales as of March 2025, even a small percentage of unmanaged conflicts can generate significant regulatory and reputational harm.

Beyond regulatory risk, poorly managed conflicts undermine the applicant experience. When charities suspect that funding decisions are influenced by personal connections rather than merit, it damages the relationship between funders and the sector they serve — exactly the dynamic that IVAR's Open and Trusting initiative, now signed up to by over 150 funders, is working to address.

Building an effective conflict-of-interest policy

A written policy is the foundation. It does not need to be long, but it must be specific enough that everyone involved in grant decisions knows what is expected of them. The Association of Medical Research Charities (AMRC) requires all its members to have a written conflicts policy covering scientific advisory panels, and this principle applies equally to any funder operating review panels (AMRC Guidance).

An effective policy should cover:

Scope. Define who is covered — trustees, staff, external assessors, volunteers, and anyone else involved in grant decisions. Include connected persons: spouses, partners, close family members and business associates.

Definition. State clearly what constitutes a conflict, using both the financial and loyalty categories from CC29. Provide concrete examples relevant to your grantmaking context.

Declaration process. Require all covered individuals to complete a declaration of interests annually, and to make ad hoc declarations whenever a new conflict arises. Declarations should be made before access to applications is granted.

Management procedures. Set out what happens when a conflict is declared: recusal from discussion and scoring, exclusion from access to the relevant application materials, or — in rare cases — a managed participation with full transparency.

Sanctions. Describe the consequences of failing to declare a conflict, which may range from removal from the panel to referral to the Charity Commission.

Review cycle. Commit to reviewing the policy at least annually.

Practical safeguards for grant review panels

Policy alone is not sufficient — it needs to be embedded in the operational workflow. For funders running panel-based reviews, practical safeguards include:

Pre-round conflict screening. Before distributing applications, share the list of applicant organisations (names only, not full applications) with all panel members. Ask each reviewer to flag any connections. This catches most conflicts before they become problems.

Controlled application assignment. Assign applications to reviewers in a way that avoids known conflicts. If a panel member declares a connection to an applicant, simply do not assign that application to them. This is far more effective than relying on reviewers to recuse themselves after having already read the application.

Blind or redacted assessment. For particularly sensitive rounds, consider removing identifying information from applications before reviewers see them. This reduces unconscious bias as well as formal conflicts. In Plinth, the assessment settings allow funders to redact applicant names, email addresses and other identifying details from external assessors' view, supporting genuinely blind review where needed. Funders can also hide specific application questions from external assessors using question-level privacy controls.

Restricted access. External assessors on Plinth can only see applications that have been specifically assigned to them. They cannot browse the full application list, cannot access due diligence or agreement tabs, and cannot see other assessors' scores. This architecture means that even if a conflict is missed at the declaration stage, the reviewer's exposure to conflicted material is limited by design.

Independent chairing. Where conflicts are complex or politically sensitive, appoint an independent chair for the relevant panel session — someone with no connection to any applicant in the round.

Meeting protocols. Establish a standing agenda item at the start of every panel meeting for conflict declarations. Record in the minutes who declared what, who left the room, and who remained for each decision.

Using technology to enforce conflict controls

Manual processes — paper registers, email declarations, reliance on individuals to recuse themselves — are better than nothing, but they depend heavily on memory and goodwill. Digital grant management systems can automate many of the controls that policies describe.

Tools like Plinth build conflict management into the workflow in several ways:

Controlled assignment. Funders assign specific applications to specific assessors or assessor groups. A reviewer who should not see a particular application is simply never assigned it — there is no application to recuse from.

Access logging. The system records who accessed which application and when, creating an automatic audit trail. If a question is raised later about whether a conflicted reviewer saw an application, the log provides a definitive answer.

Blind assessment. The option to redact applicant information means reviewers can score applications without knowing who submitted them, removing the most obvious trigger for conflicts and unconscious bias.

Assessor isolation. External assessors cannot see each other's scores (unless the funder explicitly enables this), cannot export data, and cannot access fund settings. This compartmentalisation limits the damage if a conflict is not caught.

Multi-assessor comparison. When multiple assessors score the same application, Plinth displays their scores side by side with colour-coded avatars for each reviewer. This makes it straightforward for the grants manager to spot and investigate any scoring anomalies that might indicate an undeclared conflict.

Plinth offers a free tier, making structured conflict controls accessible even to smaller funders who may not have dedicated compliance teams.

Conflicts in participatory and community-led grantmaking

A growing number of funders are involving community members, beneficiaries or people with lived experience in grant decision-making. This is welcome — it brings important perspectives — but it also increases the likelihood of conflicts. In small communities, everyone knows everyone. A community panel member may have personal relationships with applicants, may benefit from funded services, or may be involved with multiple local organisations.

The Fund for Shared Insight, which has examined conflicts in participatory grantmaking, argues that the goal is not to eliminate interconnectedness but to manage it openly. In tightly connected communities, a rigid interpretation of conflict-of-interest rules could exclude exactly the people whose perspective is most valuable.

Practical approaches for community panels include:

• Normalise declaration. Frame conflict declaration as routine, not accusatory. Everyone on the panel should expect to declare something.
• Proportionate response. Not every connection requires full recusal. A community member who uses a local service is in a different position from someone who manages it. Establish a tiered response: declare and participate, declare and abstain from scoring, or declare and withdraw entirely.
• Group accountability. Ask the panel as a whole to confirm at the end of each session that conflicts have been handled fairly. This creates collective ownership of the process.
• Clear briefing. Invest time at the start of the process explaining what conflicts are, why they matter, and what the panel should do about them. Many community panel members will not have encountered formal conflict procedures before.

Common mistakes and how to avoid them

Even well-intentioned organisations make predictable errors in conflict management. The most frequent include:

Collecting declarations too late. If reviewers declare conflicts after they have already read the applications, the damage is done — they have formed views influenced by material they should not have seen. Always collect declarations before distributing application materials.

Vague policy language. A policy that says "reviewers should avoid conflicts" without defining what a conflict is, or what to do about one, achieves nothing. Be specific, use examples, and set out the steps.

No quorum planning. If several panel members recuse themselves from the same application, you may find yourself without enough reviewers to make a valid decision. Plan for this by appointing reserve reviewers or establishing a minimum quorum in your terms of reference.

Ignoring loyalty conflicts. Organisations often focus on financial conflicts (where money changes hands) but overlook loyalty conflicts (where relationships, reputation or allegiance create bias). The Charity Commission treats both equally seriously.

Treating all conflicts the same. A reviewer who is the chief executive of an applicant charity is in a fundamentally different position from a reviewer who once attended a training event run by the applicant. Proportionality matters. A rigid one-size-fits-all approach can exclude valuable expertise unnecessarily.

No enforcement. A policy without consequences is a suggestion. If someone fails to declare a conflict, there must be a real and documented response — even if it is a formal conversation rather than immediate dismissal.

How to communicate your conflict processes to applicants

Transparency about how conflicts are managed builds applicant confidence. Funders do not need to publish the names of individual reviewers, but they should make clear:

• That a conflict-of-interest policy exists and is actively enforced
• What types of conflicts are covered
• How declarations are collected and managed
• How applicants can raise concerns if they believe a conflict has not been handled properly

Publishing a summary of your conflict-of-interest policy on your website is straightforward and signals seriousness. Several UK research charities, including Sarcoma UK and Fight for Sight, publish their conflict policies alongside their funding criteria. This approach is consistent with the transparency principles that increasingly characterise good grantmaking practice.

Where applicants do raise concerns, respond promptly and investigate genuinely. Even if the concern is unfounded, how you handle it shapes perceptions of your fairness for future rounds.

FAQs

Are minor connections — like attending the same conference — conflicts of interest?

Not necessarily. The test is whether a reasonable observer would consider the connection significant enough to influence the reviewer's judgement. Attending the same conference is unlikely to qualify; co-presenting at the same conference might. When in doubt, declare the connection and let the panel chair or grants manager decide how to handle it.

Can a trustee who sits on the board of an applicant charity still participate in the panel?

They can remain on the panel for other applications, but they must declare the conflict and withdraw from all discussion, scoring and decision-making on the relevant application. The Charity Commission's CC29 guidance is clear that a trustee of a grantmaking charity who is also a trustee of an applicant charity has a conflict of loyalty that must be managed.

Should we publish the names of our grant review panel members?

This is a judgement call. Publishing names increases transparency and allows applicants to flag potential conflicts. However, it may expose reviewers to lobbying or pressure. Many funders publish panel member names after decisions are made, or share them with applicants on a confidential basis before the round.

What happens if a conflict is discovered after a grant has been awarded?

Investigate immediately. Review the decision to determine whether the conflict could have influenced the outcome. If it could have, consider whether the decision needs to be revisited. Document everything. In serious cases — such as an undeclared financial conflict — you may need to report the matter to the Charity Commission as a serious incident.

How do we manage conflicts when using AI to assist with grant assessments?

AI tools do not have personal conflicts of interest, but the humans who configure, review and override AI recommendations do. If you are using AI-assisted assessment — for example, Plinth's Pippin AI, which can auto-generate draft assessment scores — the same conflict rules apply to anyone who reviews or adjusts the AI output. Additionally, ensure that conflicted reviewers do not have access to AI-generated summaries of applications they should not see.

Is a register of interests legally required for grant panels?

There is no standalone legal requirement to maintain a register of interests specifically for grant panels. However, the Charity Commission expects all charities to manage conflicts effectively, and a register is the most practical way to do this. For charities subject to the Charities Act 2011, failing to manage conflicts properly can constitute a breach of trustee duties.

How often should panel members update their declarations?

At minimum, annually — and additionally whenever a new connection arises. For organisations running multiple grant rounds per year, it is good practice to ask for a fresh declaration at the start of each round, since relationships and affiliations can change between cycles.

Recommended next pages

• How to Build Transparency into Grant Decisions — Communicating funding decisions clearly and building applicant trust.
• Audit Trails in Grant Software — Why digital records matter for accountability across the grant lifecycle.
• Grant Compliance in the UK: What Every Funder Must Know — Essential UK rules, Charity Commission expectations and practical controls.
• Risk Management in Grantmaking — How to identify and manage risks across your funding portfolio.
• AI vs Human Bias in Grant Decisions — Understanding how bias — both human and algorithmic — affects funding outcomes.

Last updated: February 2026