Make Conflict of Interest Policies Public
If I’m interviewing someone for a position my job is to assess their suitability as a potential employee, but if they’re my cousin I might be tempted to give them an overly favorable review. Most organizations have Conflict of Interest (CoI) policies that describe how to handle this sort of situation: it’s common that someone might have external relationships which lead to duties, interests, or desires that conflict with what’s best for their organization.
It’s reasonably common for non-profits to publish their CoI policies (Hewlett, Carnegie, Gates). Within effective altruism I do see some of this:
Animal Charity Evaluators has a great page on their policies, which includes their full CoI policies.
Open Philanthropy shares their Relationship Disclosure Policy, though I (and others) don’t see their full policy.
GiveWell has a public Conflict of Interest Policy for Board Members, Officers, and Key Persons, though probably also has an internal one for regular employees that seems not to be public? They maintain a Relationship Disclosures page, which I think is great.
Historically people and organizations within the EA movement have prioritized transparency, and while there’s been some shift away from the most enthusiastic versions of this as we’ve better understood the costs, there are still a lot of benefits. If you’re already going to the effort of drafting a policy like this, making it public seems pretty useful:
EAs who are concerned about CoIs within the community and are thinking about what norms they might try to influence can see what’s already formally in place.
Other organizations can reference it in trying to figure out what sort of policy they want.
People who are worried a situation can see what policy was (supposed to have been) followed.
On the other hand, many EA organizations don’t seem to have public policies. This includes ones that work in community building or grant-making where they seem pretty important. Here are a few I checked:
The Centre for Effective Altruism mentions that they have a “written conflict of interest policy”, but it doesn’t seem to be public.
The Effective Ventures Foundation doesn’t list anything on their site, but says in their 2021 IRS filings that “when a conflict of interest arises a plan for regularly checking in with the involved parties is done monthly as per the policy of the handbook”.
The EA Funds website repeatedly mentions their CoI policy without linking one (ex: “Potential conflicts of interest are governed by the EA Funds Conflict of Interest policy”). In the 2020-02-05 post Request for Feedback: Draft of a COI policy for the Long Term Future Fund one of their fund managers linked this document (“EA Funds Conflict of Interest Policy”) but in the discussion on the 2021-03-23 post EA Funds has appointed new fund managers they said it wasn’t yet public and in follow-up on 2022-01-13 shared a beta version in a comment.
Giving What We Can lists their major potential CoIs publicly, which is great! But it would also be good to see the policy.
Rethink Priorities and the EA Foundation say (RP, EAF) that they have written conflict of interest policies available on request, but don’t put them on their websites. [EDIT: RP replied in the comments on the EA Forum to share theirs]
I can’t find one for Charity Entrepreneurship or Founders Pledge.
I’ll write asking for policies, and will update this post if I hear anything back.
Disclosure: my wife is a GiveWell board member, former president of GWWC, and works for CEA which is part of EVF. I haven’t run this post by her and I don’t know her views here. I work at an organization that has received funding from Open Philanthropy.
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Thank you Jeff for the post. I’m Alex, Director of Operations at Charity Entrepreneurship. We have a COI policy in our staff handbook, but you’re right to say that our COI policy isn’t public at the moment, so thank you for the nudge. Recent events made us think that we could take this opportunity to review our policy and potentially strengthen it even more, particularly by comparing it to others’ policies in this post. We will take a look and can commit to publishing it on our website before the end of the month.
Hi there!
Has Charity Entrepreneurship published its CoI policy? (I didn’t find it on CE’s website.)
Hi there. As promised, here is CE’s Conflicts of Interest policy. We’re still waiting for a couple of pieces of advice to come through so the text will likely change and we’ll post an updated version. In saying that, there likely won’t be wholesale changes.
I’m curious what “does not permit” means here, since below this is written fairly modest steps.
I.e. I am aware Joey (executive director) has dated several members of staff (and still does at point of writing). Do I understand correctly Joey was not permitted to do so, but since presumably he has followed the steps described in the COI, he is permitted to continue?
To be clear, I am new to COI’s so this might be normal, plus I can see COI are not designed as a guide for good workspace culture, but to specifically mitigate a certain form of mismanagement (i.e. what would colloquially be called “corruption”).
Somewhat related question, do you expect any individual board members have COI in that all are previous founders of CE incubated charities. I am not sure I can point to any direct harms from this, but it does pattern match onto a Revolving Door. The Effective Altruism space is large, so it does seem suboptimal to have only board members that were previously in a subordinate role to the directors of CE.
Probably not all of my thoughts here are related to COI, but more towards unhealthy culture around CE and the way it operates.
Hi Ofer, apologies for the delay. We’re doing one final round of review and will be publishing it very soon. I will send you a link as soon as it’s published.
Hey, thanks for the suggestion. To save interested people from having to email us, here are links to our conflict of interest policies. We have two: one for our board and one for staff. These are probably pretty standard documents and I would think they do not differ much between organizations (except at grantmaking foundations, where I imagine they are more complicated). I expect the real value comes from really thoughtfully detecting and enforcing conflicts of interest, as opposed to having a written policy that is not well understood or enforced.
Thanks; requested access to both!
I do think you’re right that they’re often pretty boring and the important stuff is in organizational practice. In this case, though, I’m especially interested in what sort of things the policies require employees to disclose (internally), which I think probably does (or at least should) vary meaningfully?
Sorry I didn’t realize they were restricted. I’ve made both documents publicly viewable.
Thanks! I appreciate the speedy responses, though they aren’t necessary!
After I’ve been able to look at ones for a bunch of organizations I think I’ll probably do some sort of comparison.
Some things that jumped out to me on skimming these:
The board member one seems to only be concerned with financial conflicts of interest, but interpersonal ones also seem like they could be an issue?
The employee one maybe covers interpersonal stuff, but not very explicitly. For example, it’s not obvious to me under which circumstances two RP employees would need to disclose that they’ve begun dating.
We have a separate “Personal Relationship Policy” that governs disclosure around dating. The summary is that if an employee has a personal relationship with another RP employee or external stakeholder (e.g., at an EA grantmaking organization) who has perceived or real authority / influence / power to affect RP or its employees, they must disclose such a relationship.
Is there any chance you might be up for posting that policy as well? I’m interested in understanding how different organizations have decided to handle these.
Would nepotism be handled by one of these, or would that be another policy?
Hi Jeff, here is CE’s Conflicts of Interest policy. We’re still waiting for a couple of pieces of advice to come through so the text will likely change and we’ll post an updated version. In saying that, there likely won’t be wholesale changes.
Thanks!
And they should all be put on a wiki page called “conflict of interest policies”
What do you lot hate about this? Seems like a reasonable place to put them. And much more credible to be able to say “all our orgs policies are here”
I’ll go even further: policies of potential public interest should be public unless there is an articulate reason to the contrary.
Ehhh, I can see an issue with everything being transparent. I used to work in the Civil Service and trust me, the Freedom Of Information act causes a huge amount of busywork.
That said there does seem to be the general and harmful opinon that EA orgs don’t have conflict of interest policies, but they do so sharing them seems good.
I have a civil-service background as well—full FOIA would be unreasonable, but “post your policies once every few years unless there are reasons not to post certain portions” isn’t a heavy ask.
I agree Nathan, I don’t understand the downside. If it’s public, it’s public so why not just make it more easily accessible?
GiveWell has now published their Workplace personal relationships policy and Workplace personal relationships guidance, linked from here.