Conflicts-of-interest and revolving‑door influence in early decisions
Conflicts-of-interest, intermediaries, and revolving‑door movements enable undue influence over project prioritisation and early choices, including design-related choices and project location.
Red Flags & Indicators
- Conflicts-of-interest are not declared for decision makers, advisers and consultants.
- Roles, relationships (such as related-party links and beneficial ownership) and fees of advisers and intermediaries are unclear.
- Advisers and intermediaries are appointed without transparent selection and independence safeguards.
- Key meetings occur off‑record or without minutes and approvals
- Officials move to private firms soon after decisions affecting those firms and cooling-off/recusal rules are absent or inconsistently applied.
Stakeholder Guidance
Stakeholder Exposure
Exposure includes limitation to fair competition; pressure to hire connected advisers/intermediaries; reputational harm; and increased legal risk when access is transactional and conflicts are hidden.
Decision Point
Before committing resources, request clarification on any adviser/intermediary and beneficial owners of companies involved in early project shaping.
Mitigation Actions
• Require disclosure of beneficial ownership of companies and entities involved in the project
• Avoid arrangements, contracts or financial structures where parties connected to the project, the client, or the government can remain hidden and undisclosed
• Use written contracts with defined deliverables and transparent fees applied to advisers and intermediaries
• Ban/reject contractual clauses where success fees paid to advisers and consultants is linked to access, selection, or approval of projects
• Apply third‑party due diligence and conflict-of-interest checks for partners, advisers and intermediaries (including former officials)
• Maintain clear records of engagement with public officials/former officials (meetings, attendees, topics and commitments)
• Adopt internal policies regulating a cooling-off period between a public official could take up a role within the company
• Adopt a lobbying policy that sets clear limits on gifts and hospitality and applies to agents and intermediaries
• Use internal compliance escalation processes and whistleblower channels, where available, to report internally if “political access” is offered or requested
Mitigation Resources
Declare and manage conflicts-of-interest, gifts, lobbying contacts, secondary roles, and revolving-door risks affecting early project decisions and adviser appointments; exclude conflicted advisers, intermediaries, or former officials from the decision process or engagement until conflicts are resolved and documented.
Conflict-of-interest management and ethics controls — https://toolbox.infrastructuretransparency.org/resource/conflict-of-interest-management-and-ethics-controls/Screen owners, sponsors, partners, agents, advisers, and intermediaries linked to early project decisions or adviser appointments; verify beneficial ownership, PEP, sanctions, and related-party risks, and escalate concerns or decline engagement where red flags remain.
Counterparty integrity screening and due diligence — https://toolbox.infrastructuretransparency.org/resource/counterparty-integrity-screening-and-due-diligence/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes governance failures; reputational damage; debarment contagion via advisers or contractors; and project underperformance due to biased early decisions.
Decision Point
Before preparing letter of intent or term sheet, assess conflict-of-interest, adviser independence, and any revolving‑door risks. Continue only once conflict-of-interest is cleared.
Mitigation Actions
• Screen intermediaries and key counterparties for sanctions and debarment
• Include integrity covenants in term sheets and relevant agreements: no success fees linked to access or project approval; transparent terms of reference and fee schedule applicable to advisers and intermediaries; written reporting of material contacts and any lobbying relations/representation; a track record of decision; cooling-off requirements
• Include enforceable pause/suspension and exit triggers when covenants are breached, disclosures remain incomplete, cooling-off requirements are waived without documented justification, or adviser appointments create credible undue-influence risk
Mitigation Resources
Require conflict-of-interest declarations and conflict management for advisers, intermediaries, and relevant decision-makers in early project decisions; document gifts, lobbying contacts, secondary roles, and revolving-door risks, and exclude conflicted parties from the decision process until conflicts are resolved and documented.
Conflict-of-interest management and ethics controls — https://toolbox.infrastructuretransparency.org/resource/conflict-of-interest-management-and-ethics-controls/Conduct integrity due diligence on intermediaries, advisers, and key counterparties linked to early project decisions; use covenants, reporting requirements, enhanced due diligence triggers, and pause, suspension, or exit rights where red flags or undue-influence risks remain unresolved.
Investor integrity due diligence and monitoring — https://toolbox.infrastructuretransparency.org/resource/investor-integrity-due-diligence-and-monitoring/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes biased prioritisation; advice and decisions not based on credible evidence; poor project choices; higher audit, investigation and legal challenge risk; and loss of institutional credibility when conflicts are not managed.
Decision Point
Before appointing advisers and approving project selection, ensure conflict-of-interest controls are in place and verification process can be documented.
Mitigation Actions
• Maintain a conflict-of-interest register and document any waivers/exceptions with written justification
• Apply cooling‑off rules and document post‑employment restrictions for key roles
• Maintain a transparent record of meetings and lobbying relations/representation relevant to project approvals
• Use independent reviewers for high profile and mega projects and rotate panels when prior relationships/related-party links exist
• Document appointment decisions, mitigations, and the rationale for the final project recommendation
Mitigation Resources
Require conflict-of-interest declarations, maintain conflict-of-interest registers, enforce recusal, and document gifts, lobbying contacts, secondary roles, and revolving-door risks affecting early project decisions; exclude conflicted officials or advisers from the decision process until conflicts are resolved and documented.
Conflict-of-interest management and ethics controls — https://toolbox.infrastructuretransparency.org/resource/conflict-of-interest-management-and-ethics-controls/Assess corruption risks in early project decisions, including conflicts of interest, adviser influence, lobbying contacts, and revolving-door risks; assign mitigation actions to responsible units, set deadlines, and revise controls where new red flags emerge.
Institutional integrity risk assessment and mitigation — https://toolbox.infrastructuretransparency.org/resource/institutional-integrity-risk-assessment-and-mitigation/Publish and maintain public access to early project decision records, including conflict-management measures, meeting and lobbying records where disclosure rules allow, appointment decisions, and reasons for changes, waivers, or exceptions.
Transparency and data disclosure standards — https://toolbox.infrastructuretransparency.org/resource/transparency-and-data-disclosure-standards/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes captured priorities; reduced trust; and limited accountability when decisions are shaped by hidden relationships and revolving‑door influence.
Decision Point
During budget cycle allocation and/or pipeline publication, request disclosure of conflict-of-interest arrangements. Decide whether to (a) escalate through oversight channels, or (b) monitor while gathering evidence safely.
Mitigation Actions
• Use access to information to request information on conflict-of-interest declarations and beneficial ownership checks conducted in relation to officials, intermediaries and advisers
• Monitor the use of intermediaries and raise concerns with oversight bodies when a lack of transparency in the engagement of advisers and intermediaries transpires, or when other issues emerge (late appointments, repeat firms, waived cooling-off - anonymise sources and use secure reporting routes when coercion or retaliation risks are material)
• Advocate for a transparent record of meetings and lobbying relations/representation relevant to project approvals
• Advocate for a transparent conflict-of-interest register relevant to instances of project approval
Mitigation Resources
Request access to non-public decision records, such as adviser appointment records, conflict-of-interest declarations, meeting records, fee arrangements, and records of lobbying or representation relevant to early project decisions, so hidden influence, undeclared interests, or unexplained decisions can be examined and raised through oversight channels.
Access-to-information and demand-side transparency — https://toolbox.infrastructuretransparency.org/resource/access-to-information-and-demand-side-transparency/Collect and use beneficial ownership data on companies, advisers, intermediaries, and connected parties involved in early project decisions to identify hidden control, shell entities, or conflicts-of-interest.
Beneficial ownership transparency and interoperability — https://toolbox.infrastructuretransparency.org/resource/beneficial-ownership-transparency-and-interoperability/