Conflicts of interest do not always mean wrongdoing, but undisclosed conflicts can undermine procurement, hiring and partner decisions. A conflict-of-interest register helps an NGO record relationships that could influence—or appear to influence—grant decisions and shows how those conflicts were managed.
Define what must be disclosed
Staff, board members and procurement committee members should know what relationships require disclosure. This may include family connections, financial interests, close business relationships, gifts or roles in organizations that could benefit from the grant.
Record the conflict before the decision
Disclosure is most useful before a procurement, recruitment or partner selection is finalized. Record the person involved, the relationship, the decision affected and the date disclosed. Late disclosure weakens the control because the person may already have influenced the outcome.
Choose an appropriate management action
Possible responses include recusal from evaluation, independent review, additional approval or documenting why the conflict does not affect the decision. The response should match the seriousness of the relationship and any donor requirements.
Keep evidence of recusal
If someone steps out of a procurement or hiring decision, document that they did not score bids, approve the contract or influence the final selection. Meeting minutes or evaluation records can provide this evidence.
Useful register fields
- Name and role.
- Nature of the conflict.
- Decision or transaction affected.
- Date disclosed.
- Management action.
- Approver or reviewer.
- Supporting evidence.
- Status or closure date.
For procurement-specific risks, see grant supplier due diligence.
Review conflicts periodically
Relationships can change. A supplier may hire a staff member’s relative, a board member may join a partner organization, or an employee may start a side business. Update declarations periodically and whenever staff responsibilities change.
Example
A procurement committee member discovers that one bidder is owned by a cousin. The relationship is disclosed before evaluation. The committee member does not score the bids, and the remaining evaluators document the final decision. The supplier can still be considered if policy allows, but the process is transparent and traceable.
What to do next
Use the Funding Readiness Self-Check to identify governance and control gaps that could affect donor confidence.
For practical grant opportunities and funding intelligence, subscribe to Africads Grant News.
Include procurement and recruitment committees
Conflict controls should cover temporary committee members as well as permanent staff. Before evaluating bids, interviewing candidates or selecting partners, ask participants to declare relevant relationships. This makes disclosure part of the decision process rather than a yearly paperwork exercise.
Use the register to spot repeated patterns
If the same person repeatedly has conflicts involving particular suppliers or partners, leadership may need to change how that person participates in future decisions. The register can reveal patterns that individual declarations do not show on their own.
Keep management actions proportionate
Not every disclosed relationship requires exclusion. The important point is that the organization assesses the risk and documents the control used. A minor prior professional relationship may need only disclosure, while a close family or ownership interest may require recusal or a different decision-maker.
Protect the credibility of the register
Staff are more likely to disclose conflicts when the process is clear and proportionate. Treat disclosure as good governance, not as an automatic accusation. At the same time, apply the management action consistently so employees see that similar conflicts are handled in similar ways.
Keep completed declarations and related decisions with governance or grant records according to the organization’s retention policy. This makes it easier to demonstrate that conflicts were considered before material decisions were made.
Where donor rules require annual or transaction-specific declarations, build those dates into the compliance calendar. This prevents the register from becoming outdated and makes conflict management part of routine grant governance.
Frequently asked questions
What should a conflict-of-interest register include?
Record the person, relationship or interest, date disclosed, affected decision, mitigation, reviewer, and current status.
Who should disclose conflicts?
Board members, staff, procurement participants, consultants, and others with influence over grant-related decisions should follow the organization’s conflict policy.
Is disclosure enough?
No. The organization should document how the conflict was managed, such as recusal, independent review, or another control.
Who should review the register?
The appropriate governance, compliance, or leadership authority should review material conflicts and recurring patterns.
Why does this matter for donor confidence?
Transparent conflict management supports procurement integrity, governance credibility, and confidence that donor-funded decisions are made independently.
Conclusion
A conflict register is useful only when disclosures lead to proportionate action. Your organization should record the conflict, manage the affected decision independently, and preserve the evidence showing how the risk was handled.