Conflicts-of-interest and revolving-door influence in appraisal
Decision makers or advisers have undisclosed interests that influence appraisal outcomes.
Red Flags & Indicators
- Conflict-of-interest declarations for advisers, reviewers, and decision-makers involved in the appraisal process are absent, incomplete, outdated, or not independently verified.
- Appraisal officials, advisers, or reviewers hold overlapping roles or have prior professional, financial, political, or personal relationships that compromise—or appear to compromise—their independence.
- Advisers, experts, or appraisal panel members are selected through non-competitive or poorly documented processes, with unclear selection criteria, qualifications, roles, or terms of reference.
- Recusal, cooling-off, and independence safeguards are absent, applied inconsistently, or waived without documented justification during the appraisal process.
Stakeholder Guidance
Stakeholder Exposure
Exposure includes pressure to accept appraisal prepared by “connected” advisors; skewed appraisal criteria reducing access for bidders; and higher compliance and reputational risk via conflicted relationships.
Decision Point
Before considering appraisal results, verify whether conflict-of-interest and independent checks have been conducted regarding advisors and decision makers involved in appraisal.
Mitigation Actions
• Require conflict-of-interest declarations from advisers, consultants, or intermediaries engaged by the company
• Request evidence that conflict-of-interest systems are in place to manage engagement of public officials, public-sector advisers, and appraisal decision makers
• Screen former officials engaged by the company for applicable cooling-off restrictions and document results, recusals and any restrictions applied
• Use documented selection processes and clear terms of reference for advisers, consultants, and intermediaries
• Ban/reject contractual clauses where success fees paid to advisers and consultants is linked to access, selection, or approval of projects
• Adopt a lobbying policy that sets clear limits on gifts and hospitality and applies to agents and intermediaries
Mitigation Resources
Require conflict-of-interest declarations and documented conflict management for advisers, panel members, and relevant decision-makers involved in appraisal and financing decisions; exclude conflicted parties from the decision process until conflicts are resolved and documented, and record gifts, lobbying contacts, secondary roles, and revolving-door risks that could influence appraisal outcomes.
Conflict-of-interest management and ethics controls — https://toolbox.infrastructuretransparency.org/resource/conflict-of-interest-management-and-ethics-controls/Screen advisers, agents, intermediaries, and counterparties involved in appraisal and financing decisions; 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 reliance on conflicted advisors conducting appraisal processes; biased recommendations regarding risk and returns; ESG and reputational exposure if revolving‑door links emerge; decrease of project value from flawed appraisal; and higher risk of overruns and disputes.
Decision Point
Before investment committee decision, agreeing term sheet conditions and committing resources, verify whether conflict-of-interest and independent checks have been conducted regarding advisors and decision makers involved in appraisal.
Mitigation Actions
• Conduct enhanced due diligence on for advisers involved in appraisal
• Condition engagement on clear terms of reference and independence clauses for advisers involved in appraisal
• Pause investment decision and trigger independent review when appointments, undisclosed ties, or late scope/assumption changes indicate potential undue influence
• Include re-appraisal triggers for material scope and cost growth
• Include audit rights and step-in, holdback, or exit rights if feasibility risks escalate and issues are resolved
Mitigation Resources
Require conflict-of-interest declarations and documented conflict management for advisers, intermediaries, and relevant decision-makers involved in appraisal and financing decisions; record 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 advisers, intermediaries, and relevant counterparties involved in appraisal and financing decisions; require disclosure of roles, fees, commissions, beneficial ownership where feasible, prior public roles, and any waivers to cooling-off rules, and use independence clauses, audit rights, and pause, suspension, or exit rights where red flags 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 weak appraisal process; decisions more vulnerable to audit and legal challenge; biased appraisal lock in poor project options; loss of public trust; and higher renegotiation pressure.
Decision Point
Before appointing the appraisal official, conduct conflict-of-interest checks.
Mitigation Actions
• Run periodic compliance spot-checks and document any waivers/exceptions with reasons and approvals
• Document selection criteria for appointing appraisal officials and reviewers
• Adopt and enforce internal policies regulating a cooling-off period
• Assign independent appraisal reviewers when prior relationships or related-party links could affect independence of the appraisal process
• Adopt appraisal with independent review for high‑value projects
• Publish key assumptions and appraisal documentation as a transparency rule
• Maintain a meeting register and record material representations/lobbying inputs relevant to the appraisal (including via advisers/intermediaries), documenting how each input was evaluated, addressed, or rejected
Mitigation Resources
Require conflict-of-interest declarations from decision-makers, advisers, and appraisal reviewers; maintain registers, enforce recusal, apply cooling-off requirements, and document gifts, lobbying contacts, secondary roles, revolving-door risks, waivers, and mitigation measures affecting appraisal and financing decisions.
Conflict-of-interest management and ethics controls — https://toolbox.infrastructuretransparency.org/resource/conflict-of-interest-management-and-ethics-controls/Publish and maintain public access to appraisal decision records, including conflict declarations, adviser appointments, meeting registers, material representations relevant to the appraisal, approval records, and reasons for changes, waivers, or exceptions, with only lawful redactions.
Transparency and data disclosure standards — https://toolbox.infrastructuretransparency.org/resource/transparency-and-data-disclosure-standards/Failure Cases
Good Practices
Stakeholder Exposure
Exposure includes opaque adviser links; reduced transparency in appraisal; limited ability to contest appraisal assumptions; and captured decisions driving community impacts.
Decision Point
During budget cycle allocation and/or pipeline publication, request disclosure of appraisal documentation and 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 disclosure of advisors and consultants involved in appraisal, as well as their roles, contractual scope, fees/commissions, and declared interests
• Use access to information to request information on conflict-of-interest declarations and beneficial ownership checks conducted in relation to officials, intermediaries and advisers involved in appraisal
• Engage oversight bodies to raise credible concerns about unreliable and incomplete appraisal documentation or when a lack of transparency in the engagement of advisers and intermediaries transpires (use safe, confidential reporting and anonymisation where retaliation risk is 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 appraisal decision records, such as conflict declarations, adviser appointment records, meeting records, documented exceptions to cooling-off or recusal rules, and approval notes, so undisclosed interests, opaque appointments, or unexplained changes 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/Review publicly disclosed appraisal decision records, including conflict declarations, adviser appointments, meeting registers, declared interests, and approval records; identify disclosure gaps, opaque appointments, undocumented exceptions, or unexplained changes, and raise concerns about non-disclosure with an oversight body.
Transparency and data disclosure standards — https://toolbox.infrastructuretransparency.org/resource/transparency-and-data-disclosure-standards/Submit formal complaints or protected reports through oversight channels where undisclosed conflicts, opaque appointments, access-for-fee claims, or non-compliance with cooling-off or recusal rules are identified; use confidentiality and source-protection measures where retaliation risk is material.
Grievance, complaints, and protected reporting — https://toolbox.infrastructuretransparency.org/resource/grievance-complaints-and-protected-reporting/