ANAO Report No.10 2014–15 Administration of the Biodiversity Fund Program
54
provided
advice on requests for extensions for submitting applications, and
on other matters, such as procedures for distributing applications to
assessors;
provided advice in Round 1 on the design and implementation of the
‘normalisation’ process which is described in Chapter 4 at
paragraph 4.14;
attended
all meetings of the Normalisation Panels and Moderation Groups,
and provided advice where requested; and
prepared a probity report that provided an overview of the processes
undertaken for each round and the probity adviser’s certification that
these processes were defensible from a probity perspective.
3.35 Given
the complex grant assessment and selection process that was implemented
for the Biodiversity Fund program, including the involvement of a
Moderation Group discussed further in Chapter 4, having an independent probity
adviser in each funding round helped to provide the department with additional
assurance regarding the equity, accountability and transparency of the
assessment and selection processes.
Management of conflicts of interest
Grant assessors
3.36 Environment
sought the involvement of external or ‘community’ assessors
in the grant assessment process for each funding round because of their
broad community and local knowledge, as well as their technical or scientific
understanding of the complex issues involved in natural resource management.
A risk in this approach was that assessors may have professional andor
personal relationships with applicants that they are required to assess particularly
as Environment intended to allocate applications to external assessors
from their regions to draw on their local experience.
3.37 Environment
sought to manage these risks by providing appropriate training
and documented guidance to assessors in relation to conflicts of interest.
The department also put in place the following procedures, which were
outlined in the grant assessment plans for each round:
a requirement for assessors to make a conflict of interest declaration
before commencing the assessment process;
ANAO Report No.10 2014–15 Administration of the Biodiversity Fund Program
55
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.
