Conflicts of Interest in Horizon Europe

Impartial, objective, ethical, transparent. These are excellent adjectives to have for one’s business activity. They derive from concepts we instantly feel drawn to. Yet the task to define their meaning and role in a professional setting is not an easy one. We realise that even though we relate at an intuitive level, it is difficult to provide a precise description for values so profound. The case is no different when the discussion is around the subject of the present article: conflicts of interest.

What constitutes a conflict of interest? Whose interests are at stake and in what way are they opposed? Why is it something to avoid? How is it relevant in Horizon Europe projects at all? The answers are available, and we are here to guide you through them.  Let us begin by having a look at the context: the world of ethics, and more precisely, the notion of transparency.

Transparency provides clarity. It is a key feature for any organisation that wishes to operate with true efficiency, and it is indispensable for any kind of improvement, in other words, to develop and innovate. With the Horizon Europe programme having boosted the European Union’s competitiveness and growth in its focus, addressing ethical matters is paramount for the integrity of the funding scheme.

Therefore, the Grant Agreement (GA) imposes the obligation on beneficiaries to “take all measures to prevent any situation where the impartial and objective implementation of the Agreement could be compromised for reasons involving family, emotional life, political or national affinity, economic interest or any other indirect interest (conflict of interest).”

The beneficiaries’ accountability is further emphasised by the consequences set forth for non-compliance: reduction or termination of the grant or the beneficiary’s participation. The obligation is extended to the beneficiaries’ associated partners as well.

We can see from the wording of the above provision that the potential conflict is between the interests protected by the GA and any other interests which could potentially undermine it for the sake of individual gain. The Agreement seeks to protect the innovation project and the values it represents.

The beneficiaries’ responsibility to avoid any conflicts of interest is reiterated under the provisions concerning cost eligibility. The GA specifies the need to ensure that there is no breach of impartiality in awarding contracts and in implementing purchases from the grant. Goods and services procured shall be of the best possible value for the price paid. This principle, referred to as ‘best value for money’ by the GA, can only be implemented if there is no bias in the decision-making process. In other words, if there are no conflicting interests on the side of the decision-makers.

Now that we know where the conflicts could potentially stem from, we can explore the best ways to prevent them. This takes us back to our starting point: transparency. The first step to remedy both actual and perceived conflicts of interests is disclosure. Clear procedures for reporting and safety mechanisms reveal and solidify expectations within a company. Such tools can create and encourage a culture of integrity and honesty and ensure that business practices remain ethical.

Do you have questions about policies and best practice? Or perhaps you wish to know more about transparent procurement processes? We can guide you. Just contact us at