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allocation
and re‐allocation if required of applications among assessors
taking into account declared conflicts of interest; and
a requirement for assessors to declare to the Program Manager any
potential conflicts of interest arising during the assessment process as
soon as possible.
77
3.38 External
assessors were also required to complete and sign a privacy and
confidentiality deed that provided an undertaking not to access, use, disclose
or retain personal or confidential information except as part of their Biodiversity
Fund program assessment responsibilities.
3.39 In
a sample reviewed by the ANAO, all assessors had in place a conflict of
interest declaration prior to the commencement of their assessment work, as well
as a signed privacy and confidentiality deed.
78
The case study below demonstrates
how Environment managed conflict of interest situations for assessors.
Table 3.1: Case study—management of conflict of interest issues
during Biodiversity Fund program assessment processes During the assessment phase for Round 1, Environment became aware that a
community assessor had also submitted an application for funding on the basis that they had been advised during training that they could do so. The probity adviser
informed Environment that it would be unfair to exclude this application from consideration, based on the advice the assessor had received during training.
However, the probity adviser also noted that it was not ideal for project participants to have dual roles and proposed a number of strategies to minimise the probity risk
for a potentially conflicted assessor including reallocating applications similar in nature to the one submitted by the assessor. Environment did not identify any other
assessors who had also submitted an application for funding.
Source: ANAO analysis of Environment information.
Moderation Group
3.40 Potential
conflicts of interest for members of each Moderation Group were
to be managed through written declarations
79
, as well as by requiring a
77 For the NATI round, assessors were expected to report potential conflicts of interest within 24 hours.
78 The ANAO reviewed 27 declarations, representing approximately 20 per cent of assessors, across all
four rounds. 79
Conflict of interest declarations were completed by the chairs of the Moderation Group in the NATI round, Round 2 and Investing in Tasmania’s Native Forests round. However, Environment did
not retain documentation to demonstrate that the chair of the Round 1 Moderation Group had signed a conflict of interest declaration. The Round 1 probity report and the Report of the Moderation Group did,
however, indicate that the chair had made a conflict of interest declaration.
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conflicted group member to leave the room during discussion of relevant
applications. These procedures were set out in the grant assessment plans for
the NATI, Round 2 and Investing in Tasmania’s Native Forests rounds. Probity
reports prepared for each funding round indicate that these planned processes
were implemented.
Conclusion
3.41 Environment
facilitated access to each round of the Biodiversity Fund program
by planning and conducting stakeholder engagement activities, developing
grant guideline documents, and preparing for the grant assessment and
selection process. Stakeholder engagement activities to support the Biodiversity
Fund program included promotional activities, an industry roundtable
prior to Round 1, consultative meetings prior to the NATI round, surveys,
and direct correspondence with stakeholders. Overall, Environment established
appropriate arrangements to inform potential applicants about the opportunity
to apply for funding.
3.42 Grant
guidelines for the four rounds of the Biodiversity Fund program appropriately
outlined the scope, objectives and intended outcomes of the program.
While the guidelines for the three later rounds were generally clearer and
