Nature Restoration Fund: interim evaluation

Annex 5: Conflict of interest statement

Because SAC Consulting (hereafter, ‘SAC’) have previously received funding from the NRF, both as lead applicant and sub-contractors in completion of NRF projects, there is a view that a potential conflict of interest exists in relation to SAC delivering this NRF interim evaluation report. This annex provides a transparent assessment of this risk and an action plan to confirm how SAC will ensure that any conflict of interest has been suitably mitigated and continually managed.

Description of risk

SAC Consultants have applied for and led delivery of NRF-funded projects, in addition to having been subcontracted to advise and deliver NRF-funded work on behalf of other applicants. The NRF has dispensed significant funding into the land-based sector with the goal of regenerating nature, work which SAC is capable of delivering. Because SAC have delivered NRF projects, there is a risk that for Scottish Government / NatureScot that their delivery of this evaluation work may be perceived as not impartial. Specifically, SAC may, or may not be perceived to:

1. View the NRF programme favourably, as SAC has benefitted commercially from its implementation.

2. View the NRF projects in which we have played a part favourably, so as not to negatively affect the reputation of SAC / SRUC or our project partners.

3. Gain an advantage in applying for future NRF rounds of funding by gaining insight into the key success criteria for the NRF.

Actions taken to mitigate these risks

Firstly, SAC Consulting and SRUC more broadly are independent, research-based organisations and integrity is a key value that pervades their professional culture. Research and consulting projects often include sensitivities and risks of this nature, and SAC and SRUC have systems in place for keeping data separate, including GDPR consideration, which figured into the mitigation plan below.

Regarding risk #1 above – SAC, SRUC, and their employees are united behind a mission to contribute to nature restoration in Scotland. Their interests in delivering NRF projects are aligned with the overall outcomes of the fund itself. The analysis in this report was drawn exclusively from the evidence provided and collected as part of this project, with a view to exploring challenges and issues associated with the NRF and identifying areas for improvement. While process-related information emerged during case study conversations, the data primarily reflects individual project implementation challenges.

Regarding risk #3 above – The key success criteria for the NRF are clearly stated for the benefit of all applicants to NRF funding. The methods and results of this interim evaluation are publicly available, with nothing withheld or omitted. In addition, NatureScot operates a robust system to identify and manage potential Conflicts of Interest during the assessment of individual applications to NRF.

The following steps have been taken to mitigate residual risk from the above list of potential/perceived conflicts of interest, cross-cutting for all three of the identified risks:

1. Declaration of the conflict.

a. This conflict of interest was recognised by SAC/SRUC when preparing to submit a tender application for this evaluation work and a declaration was included in their tender response.

b. This annex is included in the report to provide a summary of the nature of the risk and mitigating measures.

c. Additionally, SAC has an established register where conflicts of interest are declared such that they can be appropriately evaluated, monitored, and mitigated. The details of the potential conflicts within this project have been listed there and were kept up to date. Information on that form includes the project manager / risk owner, their line manager, details of the potential conflict, likelihood and severity of risks, and mitigating steps being taken.

2. Appointment of someone not connected with NRF bids as a quality assurance lead for the evaluation report.

a. All outputs have been reviewed by an SRUC employee out with the project team who has had no previous engagement with the NRF whatsoever. This staff member has provided quality assurance for all outputs, specifically reviewing the potential conflict with reference to this document and is satisfied that all results are presented objectively, based on the data provided.

3. Where possible, exclusion of identifying information about individual projects throughout evaluation and reporting.

a. Regarding risk #2 – The goal of this work is to evaluate the success of the NRF overall, rather than that of individual projects. Many of the indicators to be used in this evaluation are quantitative and will be listed as summary statistics, without reference to any specific projects.

b. The exception to this is for case studies, where there is an in-depth focus on specific projects. Having reviewed the case study long list against the projects in which SAC have been involved, there is only 1 project which had been selected as a case study option. This project was therefore struck from the long list of potential case studies, to mitigate this risk.

The idea was discussed of excluding from the evaluation NRF projects in which SAC Consultants have played a part. It was the opinion of the SAC project team that this would potentially leave a significant data gap in the project, and that the risk associated with SAC projects is suitably mitigated via the steps above. Furthermore, SAC’s involvement in the majority of these projects has been to deliver specific, prescribed inputs, helping to action interventions identified in the successful applications. Because SAC has not been the named applicant / project owner in any of these instances, reputational risk for SAC is minimal. SAC recognise that any risks relating to perceived conflicts also apply to Scottish Government and NatureScot in terms of ensuring that the evaluation is independent and unbiased.