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Conflict of Interest Policy

Status: v0.1 Public Draft
Applies to: Governance, contribution, review, evaluation, verification, appeals, research, sponsorship, and public claims

Credibility depends on identifying and controlling interests that could influence—or reasonably appear to influence—the benchmark.

This policy covers both individual and organizational conflicts. The Independence and Institutional Firewall supplies the stricter composition, role-separation, funding, and activation rules for future human outputs.

1. Core rule

A conflict is managed through disclosure, restricted access, recusal, independent review, and a public decision record where appropriate. Disclosure alone does not cure a conflict.

No person may participate in a decision when their impartiality is materially compromised or a reasonable observer would expect preferential treatment.

2. Interests that must be disclosed

Relevant interests include:

  • current or recent employment, reporting, contracting, or board relationships;
  • ownership, investment, compensation, sponsorship, gifts, or contingent payment;
  • training, assessment, staffing, or commercial relationships affected by the decision;
  • recruiting, placement, sales, customer-success, engagement-management, or referral relationships affected by the decision;
  • family, close personal, supervisory, adversarial, or mentoring relationships;
  • authorship or ownership of evidence, cases, rubrics, products, or research under review;
  • prior participation in the evaluated work or disputed decision;
  • organizational competition or litigation;
  • access to hidden cases or confidential evaluator information;
  • public positions that create a direct commitment to a specific outcome.

Membership in a broad profession or use of a common technology is not automatically disqualifying, but may still be relevant.

3. When disclosure is required

Disclosure is required:

  • on appointment and at least annually;
  • at the start of each evaluation, appeal, release, RFC, research, funding, or procurement decision;
  • when circumstances change;
  • before receiving controlled materials.

The decision owner records whether the interest is clear, manageable with conditions, or disqualifying.

A person does not count toward the Commission’s external majority until a separate public independence determination is complete. The initial definition and 24-month affiliation lookback are in INDEPENDENCE_FIREWALL.md. This is a project policy, not a universal legal definition. Fixed, market-reasonable compensation for ordinary Commission service is not by itself disqualifying only when it satisfies the firewall's advance approval, comparable-role schedule, public disclosure, narrow service scope, noncontingency, and anti-retaliation conditions; all other compensation is evaluated under the normal lookback and matter-specific conflict rules.

4. Recusal

A recused person must not:

  • receive non-public case materials;
  • direct staff or reviewers involved in the matter;
  • participate in deliberation or informal lobbying;
  • vote, approve, or sign the decision;
  • draft the final rationale except to provide requested factual input that is identified as such.

The recusal, affected matter, and substitute decision path must be recorded. Confidential details may be minimized in the public record.

5. Individual evaluations

The following controls are mandatory for any future official result:

  • a reviewer cannot decide their own result or that of a direct report, close associate, family member, or current client;
  • a person involved in the candidate’s training cannot be the sole reviewer of the resulting capability;
  • a current trainer, or a person who trained the participant during the prior 24 months, cannot rate, adjudicate, verify, issue, or appeal the affected result;
  • a person who authored or supervised the underlying evidence cannot independently corroborate it;
  • a recruiter, staffing representative, sales lead, engagement owner, or customer-success representative cannot review candidate-private evidence or control an affected outcome;
  • original reviewers cannot decide an appeal;
  • founder and executive results require external review;
  • sponsor, customer, employee, trainee, and partner engineers follow the same released rules and may receive insufficient, disputed, failed, suspended, or revoked outcomes.

When adequate non-conflicted review cannot be formed, the result remains provisional or is not issued.

6. LockedIn firewall

LockedIn Labs may found, fund, staff, and operate the project. It may not use that role to add score credit for:

  • LockedIn employment;
  • LockedIn training or program completion;
  • placement on a LockedIn engagement;
  • use of an affiliated or third-party platform;
  • founder, executive, investor, customer, or personal relationship status.

LockedIn commercial teams must not access candidate evidence or influence evaluation outcomes except through an authorized, logged, purpose-specific role.

The neutral benchmark and any LockedIn training, employment, staffing, recruiting, placement, sales, or services pathway must remain visibly and operationally distinct:

  • commercial teams cannot nominate a person into a preferred assessment path, see candidate-private evidence, receive hidden results, select raters, set thresholds, decide credentials, or influence appeals;
  • assessors cannot route a person to LockedIn staffing, sales, training, or engagement teams and cannot be compensated based on conversion, placement, contract value, pass rate, tier distribution, or issuance;
  • training completion, product activity, employment, placement, customer status, and affiliated-platform telemetry are ineligible as score credit unless the same released evidence rule makes the underlying work product independently eligible for every participant;
  • no bundled offer may promise, guarantee, accelerate, or imply a positive result because training, assessment, or staffing services were purchased;
  • assessment data cannot flow into staffing, recruiting, sales, training, or employment systems by default. A holder may voluntarily share an approved public verification object for a disclosed purpose;
  • an affiliated link or product referral must disclose the relationship and cannot imply that the benchmark endorses, prefers, or gives privileged access to that service.

Named role owners, prohibited combinations, access rights, logs, substitute approvers, and control tests must be recorded before real-person intake.

7. Commission independence and quorum

The proposed FDE Benchmark Commission must retain an externally independent majority for every protected decision. An external member who has a matter-specific conflict is recused and does not count toward independent quorum for that matter.

LockedIn and affiliate members may contribute operational facts and participate where eligible, but they cannot form the affirmative majority for an official scoring, tier, credential, structural-entity, charter, or independence-claim decision. A loss of external-majority quorum defers the decision. It does not lower the threshold or permit a founder exception.

Founding appointments require the firewall's temporary fully external confirmation panel. Once the Commission is seated, LockedIn cannot unilaterally appoint replacements, remove an external member, direct an external member’s vote, or condition program resources on a protected decision. Successors are appointed by the Commission through an external-majority nominations committee and protected vote. An external vacancy remains external; it does not create a founder replacement right. If fewer than seven seats are occupied, only the limited interim continuity authority in the firewall remains available and no protected decision or new official output may be activated. Appointment, removal-for-cause, compensation, term, vacancy, vote, dissent, and recusal records follow GOVERNANCE.md and INDEPENDENCE_FIREWALL.md.

8. Funding and sponsorship

Sponsors may support public infrastructure, research, accessibility, security, and operations. They cannot buy:

  • a governance vote or committee seat;
  • score changes, threshold changes, or outcome removal;
  • faster scoring rules rather than faster service;
  • hidden cases, private evidence, or competitor data;
  • control over a release or appeal;
  • endorsement or signatory status.

Commission, reviewer, rater, verifier, issuer, appeal, and publication compensation cannot be contingent on pass rates, credential volume, tier distribution, placement, employer adoption, sponsor renewal, commercial conversion, a particular vote, or a position taken. Ordinary Commission compensation must follow the narrow disclosed exception in INDEPENDENCE_FIREWALL.md; payment, renewal, removal, and future work cannot reward or punish a member's vote.

Before real-person operation, the Commission must control enough protected resources to select non-conflicted reviewers and appeals personnel and to operate measurement, accessibility, privacy/security, correction, and incident functions. LockedIn funding is permitted but must be disclosed and does not make the program independently funded.

Material funding relationships and restricted purposes must be disclosed before a sponsor program is represented as operational.

9. Contributions and research

Authors may advocate for their proposal but cannot be the sole approver of a material normative change. Domain-pack and vendor contributors must disclose commercial interests and cannot alter the provider-neutral core to prefer their technology.

Research publications must disclose funders, data access, author affiliations, pre-registration status where applicable, and material analytic discretion.

10. Gifts and benefits

Reviewers and decision makers must not accept gifts, travel, hospitality, discounts, employment promises, or other benefits that could reasonably influence a pending matter.

The governing body must publish a threshold and reporting process before operations begin. Until then, people in evaluative roles should decline anything beyond nominal refreshments available equally to participants.

11. Conflict register

The project must maintain:

  • a public register of governance and material organizational interests;
  • protected case-specific records for candidate, reviewer, and appeal conflicts;
  • a record of determinations, recusals, substitutes, and exceptions;
  • the Commission’s external-independence determinations and whether independent quorum remained after each protected recusal;
  • organizational role maps covering training, employment, staffing, recruiting, sales, services, assessment, credentialing, publication, and appeals;
  • retention and access rules consistent with DATA_GOVERNANCE.md.

No governance body is described as independent until its composition and conflicts support that claim.

12. Violations

Failure to disclose or honor a conflict may lead to removal from the matter or role, re-review of affected decisions, suspension of results, research correction, contribution restriction, or other proportionate action.

An affected person must receive notice and a non-conflicted review path where privacy and safety permit. Material score impact creates a new audit event; it is not silently edited.

Related documents: CHARTER.md · INDEPENDENCE_FIREWALL.md · GOVERNANCE.md · APPEALS.md