Conflict of Interest Guidance:
Permits and Grants
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Purpose
This guidance demonstrates to all employees how [Agency]’s Conflict of Interest
Policy and Conflict of Interest Procedures will be applied in the consideration and
approval of permits and grants.
A permit is an official certificate for permission to have or do something that is
administered by an employee on [Agency]’s behalf. Permit applications may be made
by an individual or an organisation.
A grant is non-repayable funding that [Agency] disburses to recipients through its
[community grants] program.
Please read the Conflict of Interest Policy for the scope and meanings of key concepts
and definitions, as these are incorporated by reference into this guidance.
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Areas of risk for conflict of interest in allocating permits
and grants
2.1 Assessment and approval of permits
[Agency] issues permits across a range of areas including [health, building, planning]
[add or delete as required]. Processes for assessing and approving permits vary
according to the area of function.
All employees involved in decision-making processes for permits should complete a
[Disclosure of Conflict of Interest Form / Disclosure of Relevant Personal Interests
Form] and ensure that this information is kept up to date. An employee who receives a
permit application should consider (preferably at initial assessment stage) whether
they have a conflict of interest. A conflict may arise through:

a family or friendship relationship with the applicant;

a close working relationship with the applicant;

financial interests in relation to the applicant or the outcome of the application;
or

an acrimonious relationship with the applicant.
Any conflict of interest should be reported to an employee’s line manager. Steps can
then be taken to manage and, if necessary, avoid the conflict. These are as outlined in
[Agency]’s Conflict of Interest Procedures.
[Agency can use examples as required. An example is provided below,]
Agency name | Conflict of Interest Guidance: Permits and Grants
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[If a planning officer is allocated a planning application from a neighbour, there may
be a conflict of interest between the officer’s public role and personal interest (whether
this is actual, potential or perceived). The planning officer should declare the conflict
to his/her line manager, who will decide on appropriate way to manage or avoid the
conflict. This may require allocating the application to a different planning officer.]
All decisions made in relation to managing conflicts of interest should be documented.
In cases where an application is forwarded to an assessment panel for review, the
employee or line manager must ensure that all members of the panel have completed
the [Disclosure of Conflict of Interest / Disclosure of Relevant Personal Interests Form]
and disclosed any conflicts of interest to the panel chair.
[Agency] has a number of additional processes to assist employees in a regulatory
role in managing conflict of interest, including: [add/delete as required]

guidelines on considering permit applications in relation to specific function
areas;

guidelines for panel members;

processes to assist in reporting the outcome of permit applications; and

regular audits of decision making processes.
2.2 Assessment and approval of grant applications
Any conflict of interest arising in relation to [Agency’s] grants program, whether it is
actual, potential or perceived must be declared so that it can be managed or avoided.
[Agency’s grant applications are assessed by an employee and alderman; a panel
comprised of alderman, employees, community members] [add/delete as required]. All
employees [and other panel members] [delete as required] involved in decision
making processes for allocating grants must complete a [Disclosure of Relevant
Personal Interests Form / Disclosure of Conflict of Interest Form].
When a grant application is received an employee must consider, and if appropriate
disclose, whether they have conflicts of interest in relation to any of the applications.
[Employees should also disclose if they are aware of someone else on the panel with
conflicts.]
[Employees involved in selecting assessment panel members should ensure that
panel members have broad representation. Before commencing their role on the
panel, members should be given a clear idea of their role and responsibilities, as well
as panel procedures]
All assessments of grant applications should be transparent, impartial and based
upon the merit of the application.
Agency name | Conflict of Interest Guidance: Permits and Grants
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[Agency] has a number of processes to assist employees to manage conflicts of
interest risks in relation to grants, including one or more of the following: [add/delete
as required]

guidelines for employees in processes for allocating grants;

guidelines for panel members;

processes for employees to regularly report the outcome of grant decisions;

regular management or external audits of decision making processes; and

ensuring that both application processes and appeal processes in relation to
the grant decisions are well publicised.
2.3 Expectation of benefit, pecuniary or non-pecuniary, in relation to permits
and grants
If an employee receives gifts or benefits from grant or permit applicants, there is a risk
of actual or perceived bias in their decision making processes.
Benefits include in-kind incentives such as travel and other opportunities. Gifts may be
offered during or after the grant or permit decision-making processes.
An employee must be aware of the risks and consequences of receiving gifts or
benefits. These are outlined in [Agency’s Code of Conduct and/or Gifts and Benefits
policy].
If an employee receives an offer of a benefit in the context of a grant or permit
application, the circumstances must immediately be reported to the employee’s line
manager.
If an employee becomes aware of a colleague or supervisor receiving gifts or benefits
they should discuss the issues with them, and / or report the circumstances, as set out
in the Conflict of Interest Procedures.
Agency name | Conflict of Interest Guidance: Permits and Grants
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