Phase 1: Project Identification

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 advisers and intermediaries involved in the project
• 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/