Grants:Policies/WMF staff eligibility for Wikimedia Foundation funding

Policy: WMF Staff Eligibility for Wikimedia Foundation Funding

Purpose

The Wikimedia Foundation operates a number of programs to fund the work of Wikimedia volunteers and affiliates, primarily through the provision of grants. This policy describes when Wikimedia Foundation staff, and organizations that have a significant relationship with Wikimedia Foundation staff, are and are not eligible to receive funding under these programs.

Definitions

Wikimedia Foundation staff includes all employees and contractors working 20 hours or more per week for the Wikimedia Foundation, currently or at any time in the past 12 months.

An applicant has a “significant relationship” with a Wikimedia Foundation staff member if:

The applicant is an organization for which the staff member is an officer, director, or trustee;
The applicant is an organization for which the staff member works as a paid employee or contractor for 20 hours or more per week;
The applicant is an organization for which the staff member is a bank account holder or authorized signatory;
The applicant is an organization in which the staff member has a material financial interest (such as a greater than 10% ownership stake); or
The applicant is a close family member of the staff member (spouse, parent, sibling, child, stepchild, grandparent, grandchild, in-law, or domestic partner).

Eligibility

If any applicant is, or has a significant relationship with, an individual who is a “covered person” under the Conflict of Interest Policy for Wikimedia Foundation Board Members, Officers, Executives, and Key Employees:
- Follow the conflict of interest policy to determine eligibility and whether the application can be approved.
If any applicant is, or has a significant relationship with, a Wikimedia Foundation staff member who works for the Community Resources & Partnerships or Grants Administration teams:
- They are not eligible for any Wikimedia Foundation funding programs, and their application will be denied.
If any applicant is, or has a significant relationship with, any other member of Wikimedia Foundation staff:
- They must indicate and provide information about their staff relationship where requested in the application form. The information from the form will be reviewed by the Grants Administration team and the Senior Manager, Community Resources, to determine eligibility.
- Examples of staff relationships that generally will not prevent grant eligibility include:
  - Staff members serving as advisors for programmatic and operational elements related to a grant.
  - Staff member serves on the board of directors and has no direct access to WMF grant funding.

Conflicts of Interest (COI) Assessment

Once reported, the Grants Team (Grants Administration team, Regional Program Officer and the Senior Manager, Community Resources, (with Legal consultation)) will:

Review all details and gather additional information if needed.
Determine whether a real or perceived conflict exists.
Document the review and outcome.

A conflict exists when:

A Covered Person or Related Party could receive a financial or other benefit;
A Covered Person holds two roles that could influence each other; or
The situation involves parties with a significant relationship and could reasonably appear to be a conflict to others.

If no conflict is found, the review process ends, and activities may proceed.

Addressing Conflicts of Interest

If a conflict is confirmed, the Grants Team (in consultation with Legal) must decide whether the activity or transaction can proceed under certain conditions, or must be stopped.

Approval

A transaction involving a conflict may only proceed if:

All relevant facts and relationships have been fully disclosed;
The transaction is not self-dealing or otherwise prohibited by law;
It demonstrably benefits the Foundation and serves its mission;
Costs are fair and reasonable compared to market standards;
No better alternative is reasonably available that avoids the conflict; and
The transaction does not involve hiring a former Foundation Trustee within the previous six months.

All decisions must be documented, including rationale and any conditions imposed.

Policy Violations

If the Grants Team has reason to believe a Covered Person or person with a significant relationship has:

Failed to disclose a conflict, or
Violated this policy,

They will:

Inform the individual of the concern and request an explanation;
Conduct further review if needed;
Determine whether a violation occurred; and
Recommend corrective action, if appropriate.

In this instance, the team will involve the Legal and People teams.

Policy Administration

The Grants Team is responsible for:

Receiving and reviewing all conflict disclosures related to grants;
Maintaining complete documentation of all reviews and decisions;
Ensuring transparency and fairness in decision-making; and
Periodically reviewing and updating this policy with Legal to ensure alignment with Foundation standards.

Key Principle

When in doubt, disclose. Staff members must avoid even the appearance of personal benefit or bias when carrying out Foundation work.

Appendix A: Conflict of Interest Review Process — Grants Team Workflow

To ensure that all potential or actual conflicts of interest (COIs) related to grantmaking are identified, reviewed, and resolved in a transparent and consistent manner. This process is designed to support staff, uphold trust in the Foundation’s grant programs, and maintain compliance with legal and ethical standards.

Trigger: Disclosure or Identification

Who: Any staff member or other Covered Person or applicant with significant relationship with staff member

Action:

Staff submits a COI Disclosure information on email or through the application form to the Grants Team and/ or Program Officer as soon as a potential or perceived conflict is known.
If a potential COI is observed by another staff member, they may report it confidentially to the Grants Administration Team & Program Officer.
Grant applicant notifies the Grants Team and/ or Program Officer of potential or perceived conflict .

Output: Logged case entry in the Internal Grants COI Register (maintained by Grants Administration).

Initial Review & Logging

Lead: Grants Administration Representative

Participants: Program Officer (PO) + the Senior Manager, Community Resources, (with Legal consultation)

Action:

Acknowledge receipt of disclosure within 3 business days.
Confirm that the information provided is complete; if not, request additional details.
Record the case in the COI tracking register (with unique grant / staff ID, date, parties involved, and status).

Outcome: Case status marked as “Under Review.”

Preliminary Assessment

Leads: Grants Administration Rep + Program Officer

Action:

Review facts, roles, and relationships described in the disclosure.
Determine whether the conflict appears:
- Actual (direct and existing conflict),
- Potential (could reasonably develop into a conflict), or
- Perceived (could appear to an external observer as a conflict).

Output: Short summary report (1–2 paragraphs) outlining key details and recommendations for the next step.

Escalation to the Review Panel

Composition:

Grants Administration Representative ( for compliance )
Program Officer (for contextual insight)
Senior Manager, Community Resources (decision authority)
Legal Representative (advisory role)

Action:

Review the summary report and supporting materials.
Review discussion focus on:
- Level / Degree and nature of the conflict;
- Applicability of the Grants COI policy or other + precedent cases;
- Recommended course of action.

Meeting: Convened within 5–7 business days of initial submission.

Documentation: Meeting notes, analysis, and decisions are captured in the COI Register and saved in the grants documentation.

Determination

Lead Decision: Senior Manager, Community Resources (in consultation with Grants Administration and Legal)

Possible Outcomes:

Determination	Description	Example Actions
No Conflict	No real, potential, or perceived COI exists.	Proceed as normal; close the case.
Manageable Conflict	COI exists but can be managed with clear conditions.	Proceed with safeguards (e.g., staff recusal, delegated decision-making, signatory limits, staff limited access to funds).
Material Conflict	Significant COI that risks impartiality or reputational harm.	Activity paused or reassigned; requested transaction declined.

Output: Written COI Determination Summary (1–page memo) outlining rationale, decision, and any conditions.

Communication of Decision

Who: Grants Administration Representative and /or Senior Manager, Community Resources

Action:

Notify the applicant of the decision in writing.
Notify the staff member (and any affected teams) of the decision in writing.
If conflict is manageable, provide explicit conditions (e.g., recusal, limits, oversight, or periodic review).
Ensure Legal and HR (if applicable) are copied where appropriate.

Timeline: Within 3 business days of panel decision.

Documentation & Record-Keeping

Leads: Grants Administration

Action:

File all related documentation (disclosure form, communications, notes, and final determination) in the COI Register and the corresponding grant file.
Mark the case as “Closed” or “Ongoing with Conditions.”
Maintain records for audit purposes aligned with current approaches.

Monitoring and Follow-Up

Lead: Program Officer (if the conflict involved a grant partner)

Action:

Ensure compliance with any conditions (e.g., staff recusal from reviews, limited access, alternate reviewers assigned).
Update the status in the COI Register every funding round and major grant stage (mid-learning conversation).
Escalate to the Grants Admin and Senior Manager, Community Resources if new facts arise.

Annual Review and Reporting

Lead: Grants Administration Team

Action:

Compile an annual summary of COI cases (number, type, resolution status).
Submit to the Senior Manager, Community Resources and Legal for review.
Identify any trends or areas for policy clarification.

Summary Workflow Table Format

Step	Grants Administration	Program Officer (PO)	Senior Manager, Funding Programs	Legal Representative	Target Timeline	Lead
1. Disclosure / Identification	Receive the COI disclosure form and log in COI Register.	—	—	—	Immediately upon awareness	Staff Member
2. Initial Review & Logging	Acknowledge within 3 business days; verify completeness.	Provide context in relation to the grantee partner	—	—	Within 3 business days	Grants Admin
3. Preliminary Assessment	Lead review with RPO; classify as actual, potential, or perceived conflict.	Provide contextual insight and confirm facts.	—	—	Within 5 business days	Grants Admin + RPO
4. Review Panel Evaluation	Chair panel meeting; prepare materials and summary.	Participate, share grant-specific insight.	Participate and lead decision-making.	Provide legal guidance and ensure compliance.	Within 7 business days of disclosure	Grants Admin (Chair)
5. Determination	Record decision outcomes.	Support risk analysis and contextual review.	Make final decision (in consultation with Legal).	Validate the decision and confirm it aligns with policy and US law.	Within 2 business days of the panel	Grants Admin + Senior Manager + Legal
6. Communication of Decision	Notify staff member in writing; record conditions.	Copy relevant team(s) for implementation.	Approve communication and conditions.	Review communication for sensitive matters.	Within 3 business days post-decision	Grants Admin
7. Documentation & Record Keeping	File all materials and update the COI Register.	—	—	Ensure records meet retention standards.	Ongoing; finalise within 5 days of decision	Grants Admin
8. Monitoring & Follow-Up	Track compliance; remind of obligations.	Monitor regional adherence to conditions.	Oversee major compliance issues.	Advise on new or escalating risks.	Ongoing throughout the grant cycle	RPO + Grants Admin
9. Annual Review & Reporting	Compile annual COI report.	Contribute data for regional cases.	Review the report and endorse findings.		End of fiscal year	Grants Admin + Legal

Appendix B: Conflict of Interest Disclosure Form

To be completed by: All staff or contractors involved in grantmaking, partnerships, or related activities. The Grants Team may fill in this information on behalf of the applicant and staff member.

1. Personal Information

Full Name:
Position at Wikimedia Foundation:
Department:
Date:

2. Description of the Relationship or Situation

Describe the nature of the relationship, activity, or external role. Include the start and end date for this relationship

3. Parties Involved

Name(s) of related person(s) or organization(s):

4. Nature of Potential Conflict

Financial interest
Family or personal relationship
Board or leadership role in a grantee organization
Involvement in a grant proposal or application
Other (please describe):

5. Steps You Have Taken to Avoid or Manage the Conflict

Appendix C: Quick Decision Guide — “Am I in a Conflict of Interest?”

Use this checklist before submitting or participating in any grant-related decision or activity:

Question	If “Yes” or “Maybe” → Disclose immediately
Do I (or someone close to me) have a personal or financial interest in this project or organization?
Am I named in, or do I help prepare, a grant proposal and report to the Foundation?
Do I serve on the board or advisory group of a grantee or applicant?
Could my Foundation staff or contractor role influence, or appear to influence, a grant decision involving someone or organization I know personally?
Would this situation look questionable to someone outside the Foundation?

If any box is checked “Yes” or “Maybe”:

Stop and disclose to the Grants Administration Team before proceeding.