Disclosure Conflict Interest_ Nov 2023_508v

PROGRAM CYCLE
EVALUATION
TOOLKIT

DISCLOSURE OF REAL OR POTENTIAL
CONFLICT OF INTEREST FOR
EXTERNAL EVALUATIONS

This document includes a template for disclosure of real or potential conflict of interest for USAID
external evaluations and instructions.

Instructions
Evaluations of USAID activities will be undertaken so that they are not subject to the perception or reality of
biased measurement or reporting due to conflict of interest.1 For external evaluations, all external evaluation
team leaders and team members will provide a signed statement attesting to a lack of conflict of interest or
describing an existing conflict of interest relative to the activity being evaluated.2 USAID employees who
participate as a team member on an external evaluation should not complete this form.
Evaluators of USAID activities have a responsibility to maintain independence so that opinions,
conclusions, judgments, and recommendations will be impartial and will be viewed as impartial by third
parties. External evaluators and evaluation team members are to disclose all relevant facts regarding real
or potential conflicts of interest that could lead reasonable third parties with knowledge of the relevant
facts and circumstances to conclude that the evaluator or evaluation team member is not able to
maintain independence and, thus, is not capable of exercising objective and impartial judgment on all
issues associated with conducting and reporting the work. Operating Unit leadership, in close
consultation with the Contracting Officer, will determine whether the real or potential conflict of
interest is one that should disqualify an individual from the evaluation team or require recusal by that
individual from evaluating certain aspects of the activity(s).
In addition, if evaluation team members gain access to proprietary information of other companies in the
process of conducting the evaluation, then they must agree with the other companies to protect their
information from unauthorized use or disclosure for as long as it remains proprietary and refrain from
using the information for any purpose other than that for which it was furnished.3
REAL OR POTENTIAL CONFLICTS OF INTEREST MAY INCLUDE, BUT ARE NOT LIMITED TO:
1. Immediate family or close family member who is an employee of the USAID operating unit
managing the activity(s) being evaluated or the implementing organization(s) whose
activity(s) are being evaluated.

USAID Evaluation Policy; USAID Contract Information Bulletin 99-17; and Federal Acquisition Regulations (FAR) Part 9.5,
Organizational Conflicts of Interest, and Subpart 3.10, Contractor Code of Business Ethics and Conduct.
2 USAID Evaluation Policy
3 FAR 9.505-4(b)
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DISCLOSURE OF REAL OR POTENTIAL CONFLICT OF INTEREST
2. Financial interest that is direct, or is significant/material though indirect, in the implementing
organization(s) whose activities are being evaluated or in the outcome of the evaluation.
3. Current or previous direct or significant/material though indirect experience with the
activities being evaluated, including involvement in the activity design or previous iterations
of the activity.
4. Current or previous work experience or seeking employment with the USAID operating
unit managing the evaluation or the implementing organization(s) whose activity(s) are being
evaluated.
5. Current or previous work experience with an organization that may be seen as an industry
competitor with the implementing organization(s) whose activity(s) are being evaluated.
6. Preconceived ideas toward individuals, groups, organizations, or objectives of the particular
activities and organizations being evaluated that could bias the evaluation.
PRIVACY ACT STATEMENT
AUTHORITY: The Foreign Assistance Transparency and Accountability Act (2016) and The Foundations
for Evidence Based Policy-Making Act (2019) enhance the transparency, accuracy, and reliability of
USAID program and activity evaluations. USAID ADS 201mah, USAID Evaluation Report Requirements,
states that an evaluation must include as an annex signed disclosures of conflicts of interest from
evaluation team members.
PURPOSE: The form USAID Disclosure of Real or Potential Conflict of Interest for External Evaluation
Team Members collects information in order identify any conflicts of interest that could create bias or
influence data analysis, findings, and or recommendations presented in the evaluation report. The
purpose of the form is to support transparency of USAID’s data collection and reporting. The form is in
a table format and requests the following information: name, title, organization, evaluation position,
evaluation award number, USAID activities evaluated, and real or potential conflicts of interest to
disclose (yes/no). USAID will use this information to determine the validity, accuracy, and reliability of
the evaluation findings.
ROUTINE USES: Because the disclosure of conflicts of interest is included as an annex in the evaluation
report, the information will be disclosed to any reader of the report in or outside of the Agency. This
will allow the reader to determine the validity, accuracy, and reliability of the evaluation findings. For
other uses, see USAID-27: Partner Vetting System, published 77 FR 2319, (December 05, 2012);
modification published 87 FR 3109 (January 14, 2021)
DISCLOSURE: This PII collection is voluntary. If the individual does not provide all or any part of the
requested information, then the transparency of the evaluation methodology is reduced and bias may
contribute to erroneous analysis, findings, and recommendations. Biased evaluation reports may
negatively impact USAID’s program cycle including decision-making, program planning, budget allocation,
and processes of collaboration, learning, and adapting.

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DISCLOSURE OF REAL OR POTENTIAL CONFLICT OF INTEREST

TEMPLATE: USAID Disclosure of Real or Potential Conflict of Interest for
External Evaluation Team Members
Name
Title
Organization
Evaluation Position

☐ Team Leader
☐ Team member

Evaluation Award Number
(contract or other instrument)
USAID Activity(s)
Evaluated (Include activity
name(s), implementer name(s) and
award number(s), if applicable)
I have real or potential
conflicts of interest to
disclose.

☐ Yes
☐ No

If yes answered above, I
disclose the following
facts:
Real or potential conflicts of interest
may include, but are not limited to:

1. Close family member who is an

employee of the USAID
operating unit managing the
activity(s) being evaluated or the
implementing organization(s)
whose activity(s) are being
evaluated.

2. Financial interest that is direct,

or is significant though indirect,
in the implementing
organization(s) whose activities
are being evaluated or in the
outcome of the evaluation.

3. Current or previous direct or

significant though indirect
experience with the activity(s)
being evaluated, including
involvement in the activity
design or previous iterations of
the activity.

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DISCLOSURE OF REAL OR POTENTIAL CONFLICT OF INTEREST
CONTINUED
If yes answered above, I
disclose the following
facts:
Real or potential conflicts of interest
may include, but are not limited to:

4. Current or previous work

experience or seeking
employment with the USAID
operating unit managing the
evaluation or the implementing
organization(s) whose activity(s)
are being evaluated.

5. Current or previous work

experience with an organization
that may be seen as an industry
competitor with the
implementing organization(s)
whose activity(s) are being
evaluated.

6. Preconceived ideas toward

individuals, groups,
organizations, or objectives of
the particular activities and
organizations being evaluated
that could bias the evaluation.

I certify (1) that I have completed this disclosure form fully and to the best of my ability and (2) that I
will update this disclosure form promptly if relevant circumstances change. If I gain access to proprietary
information of other companies, then I agree to protect their information from unauthorized use or
disclosure for as long as it remains proprietary and refrain from using the information for any purpose
other than that for which it was furnished.
Date
Signature

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