Conflict-of-Interest PolicyRules for managing conflicts of interest

This page describes ACF's approved policy, not confirmation of completed annual disclosures. The intended scope covers people involved in reviewing applications, authorizing awards, or overseeing finances.

A real, potential, or apparent conflict should be considered before a related decision. A relationship does not by itself prove wrongdoing; disclosure and independent review are the safeguards.

The person would describe the relevant interest before participating. Unconflicted decision-makers would consider whether recusal is necessary and record the interest, the handling decision, and who participated.

Questions about an actual concern can be sent through Contact Us. Do not assume this policy provides an independent investigation service or a confidential reporting portal.

Grantmaking only deserves trust when decisions are made on the merits. This policy exists to make sure personal, financial, or family interests never quietly shape who receives funding.

• Disclose any financial or personal interest
• Abstain from related discussions and votes
• Record disclosures in minutes
• Review disclosures annually

• A financial interest in an applicant organization
• A family or close personal relationship with an applicant
• A business relationship with an applicant
• Any circumstance that could reasonably appear to bias a decision

Under the policy, disclosures would be recorded in meeting minutes, and a person with a conflict would take no part in the related decision. Questions about this policy can be raised through the Contact Us page.