Thanks for this post. Overall, it seems like a great move to develop a formalised COI policy and to seek public feedback on the draft. I think these types of policies are useful for two main reasons. The first is reaching reliably good decisions. The second is giving people justified confidence in the decision-making process. Often the second reason is somewhat neglected. A lot of potential damage is from people losing trust in a process rather than from real misuse of power, but it is easy to just focus on preventing COIs rather than ensuring justified public trust. To address this, I think the pub test is actually one pretty good benchmark for a COI policy (i.e. if you asked the patrons of an average pub, would they think it seems legitimate or fishy).
To pass the pub test, I think it is important to have a process for reporting any potential COIs that could be perceived as influencing a decision. By that, I mean any relationship or connection that a reasonable person could believe might have influenced a decision. Because that is quite a strict standard, it seems too invasive to require all of these potential COIs to be disclosed publicly. To address this, you can require that any potential COI be reported to a third party within the organisation who will determine a management approach for the COI. This can be quite a quick process, just requiring one email exchange and some formal record of the decision. The management approach could include recusal, publicly disclosing the COI, or other options like seeking an extra opinion on a grant or allowing the decision to be made without needing any changes to the process. The third party’s management approach decision could also be informed by more explicit guidelines like the ones detailed in this post, but having the third party decision helps to prevent unanticipated COI circumstances from slipping through.
This third party could take the form of a small board, as has been suggested in other comments, but it could also be something else like another fund member or someone at CEA. I’m not really best placed to know who would combine the right amount of context with sufficient independence and efficiency. The main thing would be that this disclosure and management approach are formally (but not by default publicly) recorded, and are available if any concerns are raised about a potential COI.
A similar model is used in the Australian Public Service (including for COIs in grant making). Any potential real or perceived COI is disclosed to the agency head or a senior manager who then determines how the COI will be managed and the details are recorded in a COI declaration. More details of that process are here. The declaration and decision are not public, but records are kept in case the issue comes up in the future.
Adopting something like this could be a good way to get the right mix between justified public trust and non-invasiveness regarding privacy.
Thanks for this post. Overall, it seems like a great move to develop a formalised COI policy and to seek public feedback on the draft. I think these types of policies are useful for two main reasons. The first is reaching reliably good decisions. The second is giving people justified confidence in the decision-making process. Often the second reason is somewhat neglected. A lot of potential damage is from people losing trust in a process rather than from real misuse of power, but it is easy to just focus on preventing COIs rather than ensuring justified public trust. To address this, I think the pub test is actually one pretty good benchmark for a COI policy (i.e. if you asked the patrons of an average pub, would they think it seems legitimate or fishy).
To pass the pub test, I think it is important to have a process for reporting any potential COIs that could be perceived as influencing a decision. By that, I mean any relationship or connection that a reasonable person could believe might have influenced a decision. Because that is quite a strict standard, it seems too invasive to require all of these potential COIs to be disclosed publicly. To address this, you can require that any potential COI be reported to a third party within the organisation who will determine a management approach for the COI. This can be quite a quick process, just requiring one email exchange and some formal record of the decision. The management approach could include recusal, publicly disclosing the COI, or other options like seeking an extra opinion on a grant or allowing the decision to be made without needing any changes to the process. The third party’s management approach decision could also be informed by more explicit guidelines like the ones detailed in this post, but having the third party decision helps to prevent unanticipated COI circumstances from slipping through.
This third party could take the form of a small board, as has been suggested in other comments, but it could also be something else like another fund member or someone at CEA. I’m not really best placed to know who would combine the right amount of context with sufficient independence and efficiency. The main thing would be that this disclosure and management approach are formally (but not by default publicly) recorded, and are available if any concerns are raised about a potential COI.
A similar model is used in the Australian Public Service (including for COIs in grant making). Any potential real or perceived COI is disclosed to the agency head or a senior manager who then determines how the COI will be managed and the details are recorded in a COI declaration. More details of that process are here. The declaration and decision are not public, but records are kept in case the issue comes up in the future.
Adopting something like this could be a good way to get the right mix between justified public trust and non-invasiveness regarding privacy.