Would your grant decisions stand up to a probity complaint?

The question this answers

 

How do we make sure decision-makers act appropriately and can prove it?

 

What the problem looks like without probity protocols for panels and decision-makers

 

Your panel meets to assess applications. One member knows an applicant personally. Another has a professional relationship with a competing organisation. A third isn’t sure what they’re allowed to discuss outside the meeting.

No one declared anything because no one asked. No one signed anything because there was nothing to sign. No one was briefed on confidentiality because it was assumed to be obvious.

Six months later, an unsuccessful applicant alleges bias. You have no declarations, no briefing record, no documentation that probity was addressed at all.

The panel might have acted impeccably. But you can’t demonstrate it.

 

What I deliver

 

A complete probity protocol for anyone involved in grant decisions, including:

 

Guidance documents:

  • What constitutes a conflict of interest (actual, perceived, potential)
  • How to identify and declare conflicts
  • What happens when a conflict is declared (stand aside, manage, proceed with caution)
  • Confidentiality obligations (what can and can’t be discussed, with whom, when)
  • Appropriate conduct (no lobbying, no pre-commitment, no post-decision favours)

 

Ready-to-use tools:

  • Conflict of interest declaration form (for panel members to sign before each meeting)
  • Confidentiality undertaking (for anyone with access to application information)
  • Probity briefing script (for panel chairs to deliver at the start of each meeting)
  • Conflict register template (for recording all declared conflicts and how they were managed)

 

What good looks like vs what bad looks like

 

Bad: An email to panel members that says “please let us know if you have any conflicts of interest.”

No definition of what counts. No formal declaration. No record of who responded and what they said. No documentation of how conflicts were managed.

 

Good:

Conflict of interest declaration (example):

“I declare that, to the best of my knowledge:

  • I have no personal, professional, or financial relationship with any applicant that could affect, or could reasonably be perceived to affect, my impartiality
  • I have no interest in the outcome of any application beyond my role as an assessor
  • I will immediately disclose any conflict that arises during the assessment process

 

Conflicts to declare (if any):

Signature: _____________ Date: _____________”

 

Conflict register (example):

Panel memberConflict declaredNature of conflictManagement actionApproved by
J. SmithYesBoard member of Applicant 12Stood aside from assessment and discussion of App 12Panel Chair
A. JonesNo
M. LeeYesFormer employee of Applicant 7 (ended 2019)Disclosed; Chair determined no current conflict; participated with disclosure notedPanel Chair

 

Now every conflict is documented, every management decision is recorded, and the process can withstand scrutiny.

 

Why it matters

 

Probity isn’t about assuming the worst of people. It’s about protecting them.

Panel members need to know what’s expected. They need a clear process for declaring conflicts. They need confidence that if they follow the process, they’re protected.

And the program needs documentation. When someone alleges bias or improper conduct, the response isn’t “we trust our panel members.” It’s “here’s the declaration they signed, here’s the briefing they received, here’s how the conflict was managed.”

Probity protocols turn good intentions into defensible process.

Other Fraud, Risk & Probity Deliverables

 

Do You Actually Understand Your Grant Program’s Fraud Risks? → Fraud and corruption risk architecture designed around how your program actually operates. Vulnerabilities are identified at the design stage, with risk treatments built into program structure rather than layered on as compliance documentation.

 

Are your grant program integrity controls mapped to real risks? → A control architecture where every identified risk has a defined control, a named owner, and a monitoring mechanism. Gaps are visible by design. Accountability is structural, not assumed.

more Deliverables