Decisions on project selection must comply with the general principles and rules for the award of grants defined in the Programme Implementation Agreement. The Programme Implementation Agreement contains general principles and rules applicable to all selection procedures and grant awards, in addition to a general and broad outline of the selection procedure that may be deviated from in case of selection of small projects. In other words, the rules for selection procedures allows for flexibility and the possibility of proposing different selection procedures for smaller grants.  

12.1 General principles and rules

The general principles for the selection and the award of the grants are:

1. Good governance, transparency, equality, efficiency, and zero tolerance for corruption.

The general rules applicable to all types of selection procedures are:

1. Preventing conflict of interest.
2. Separation of roles and responsibilities.
3. Documentation and archiving of assessments and decisions.
4. Notification of applicants.

Preventing conflict of interest is a fundamental element of the selection procedures that should be respected and followed at all times to ensure the objectivity and integrity of the selection procedure.

It is of utmost importance that the Fund Operator ensures that the selection procedures are carried out in a way that guarantees the integrity and the objectivity of the selection process. Thus, the Fund Operator shall take every reasonable measure to prevent a conflict of interest situation from occurring in the selection process. If such a situation arises, the Fund Operator shall take all necessary measures to avoid that such a situation affects the integrity of the selection process. 

A situation of conflict of interest arises when a person involved in the selection process has a direct or indirect interest with one or more of the applications or applicants. This can happen for example by way of economic, political, family, emotional, personal or professional ties that in one way or another jeopardise that person’s impartiality and/or objectivity. 

Any person who is involved in the selection process could eventually find themselves in a conflict of interest situation, including independent experts, members of selection committees, staff involved in review of compliance with administrative and eligibility criteria, members of the board of the Fund Operator, etc. 

Examples of conflict of interest:

First example: A staff member of the Fund Operator previously worked for one of the applicants. The staff member signals this in the declaration on conflicts of interest. The head of the Fund Operator thus decides that the staff member cannot participate in the selection process, as it could put the integrity of the process at risk.

Second example: An expert is close friends with the staff of several applicants. The expert discloses this information but does not consider it to be a conflict of interest, as they believe that the assessment could be performed in an objective manner. The Fund Operator removes the expert from the selection process, as this situation constitutes emotional ties that could hinder the integrity of the selection process  and could be perceived as conflict of interest by third parties. 

One of the most important tools for the Fund Operator is ensuring that all people involved in the selection process sign a conflict of interest declaration. The template of the conflict of interest declaration should include the definition of “conflict of interest” in order for the person to sign it in full understanding of the requirements. 

Examples of measures to remedy a conflict of interest situation:

Example with Experts: The experts shall receive the list of applicants prior to receiving the project applications for assessment. The expert shall sign a no conflict of interest declaration, and together with the declaration the expert shall disclose all applicants on the list that they are associated with (direct or indirect interest). The Fund Operator shall distribute the applications in such a manner that experts who have known conflicts of interest are not invited to assess projects which they are associated with.

Example with Selection Committee: In case a selection committee member is in a situation of conflict of interest related to one or several project applications, the selection committee member should preferably not be involved in the assessment of any project application under the call in question. Should this not be feasible, the selection committee member should, as a minimum, leave the room while the project causing the conflict of interest is discussed. It is also recommended that the Fund Operator keeps a record of all conflict of interest situations.

Conflict of interest situations can be present with one or several applicants or applications. The Fund Operator shall thus ensure that the people participating in the selection process have an overview of the applications and applicants prior to assessing them. 

The conflict of interest shall be assessed in relation to all calls conducted by the Fund Operator, and declarations shall be signed by all people involved for each selection process separately, including staff members of the Fund Operator, and selection committee members. 

Separation of roles and responsibilities is a requirement entailing that people assessing project applications should not be the ones making the final decisions on funding.

It is required that multiple people are involved in the selection process, no matter the size of the grant. Having someone assess the applications and someone else take the decision to support the projects based on the first assessment ensures a minimum of diligence in the selection process and contributes to reducing the risk of unequal treatment. 

Even in case of simplified procedures, when there is no Selection Committee it should be ensured that the final decision is not made by persons who were involved in the previous stage(s) of the selection process.

Documentation of assessments and decisions is a requirement that is a central point for ensuring the transparency of the selection process.

Documentation can be done both electronically and on paper. However, it is recommended that the Fund Operator uses a clear and transparent system for documentation. It is preferable that draft and final version are clearly marked, and if possible, ensure that final versions are tamper-proof. Some examples of assessments and decisions that need to be documented include: 

• Assessment of administrative and eligibility criteria, decisions on these criteria.
• Assessment of the experts.
• Minutes of the selection committee.
• Final decision of the Fund Operator’s Steering Committee on project selection.

The Fund Operator must notify applicants of results. The information to applicants of the selection results must be shared within a reasonable time.

These general principles and rules apply even in case of selection of small projects, where the grant amount does not exceed €25,000 and a simplified selection procedure can be followed. 

Not complying with these general rules and principles is considered a serious breach of the Programme Implementation Agreement.

12.2 Selection criteria

Administrative criteria are conditions for accepting the project application. Without compliance with the administrative criteria, the application should not be further assessed. The administrative criteria should be easily determinable, meaning that their verification should not require any review of the content of the application.

• Selection criteria normally include administrative, eligibility and award criteria. 
• These criteria should be clearly distinguished and shall be specified in the call for proposals.  
• The criteria published in the open call shall be the only criteria used during the selection process.

Administrative criteria include (but are not limited to) the following: 

• The project application has been submitted by the deadline, i.e. the date and time as published in the call text.
• The project application has been submitted in accordance with the permissible method(s) of delivery (using an online tool, number of copies, electronic/and or hard copies, signatures, etc.).
• All requested documents have been submitted (e.g. declarations, documents for registry, annual reports, partnership statements, etc.).

The call text should clearly indicate: 

• Whether the Fund Operator may request additional information/documents from the applicant to determine the compliance with these criteria and, if so:

1. The time available and the method for the submission of such information/documents
2. The criteria that could lead to automatic rejection of the project application, in case of non-compliance with them

Eligibility criteria are conditions to assess whether the applicant/partner and the application are qualified for funding. It should be clear whether the criteria relate to the eligibility of the applicant or the eligibility of the application. Ideally the eligibility criteria should be assessed only once it has been determined that the application has fulfilled the administrative criteria.

Eligibility criteria could include conditions, such as:

• Eligibility of applicant:

1. The applicant is a CSO, in line with the definition provided in the Programme Implementation Agreement. 
2. The applicant respects the common values and principles described in chapter 3, in line with the requirement in Article 7.1.5 of the Programme Implementation Agreement.
3. The applicant complies with the time and for registry requirements (e.g. established at least a year ago in the Beneficiary State).

• Eligibility of partner:

1. The call text clearly defines what type of organisations are eligible as project partners, in line with the provisions provided in the Programme Implementation Agreement.

• Eligibility of application:

1. The requested grant amount is within the permissible limits provided in the call.
2. The proposed implementation period is within the permissible limits provided in the call.
3. No more applications have been submitted by one project promoter or project partner than explicitly authorised in the call text.

Normally, compliance with eligibility criteria is unconditional and therefore not subject to further clarifications requested by the Fund Operator. However, should the Fund Operator decide that some of the eligibility criteria need to be clarified by additional information, this should be clearly stated in the call for proposals, together with the deadline and method to comply with such a request. The call text should also clearly list the criteria that would lead to automatic rejection, in case of non-compliance with them.

The use of administrative and eligibility criteria shall be transparent, and easily determinable. The volume of these criteria should be limited to the essentials. Ambiguous or superfluous criteria can be subject to complaints and appeals, and thus prolong or hinder the selection procedure, and result in an additional administrative burden for the Fund Operator.

It is recommended that the Fund Operator provides a checklist in the call text and/or guide for applicants, which enables the applicant to self-assess whether they have complied with all administrative and eligibility criteria. This checklist could also serve as guidance for the applicant to indicate whether the requested information can be subject to later submission (request for clarification/additional information) or if the lack of compliance with the requested submission of information results in automatic rejection.

Award criteria are criteria used to assess the project applications that comply with the administrative and eligibility criteria. The assessment criteria shall form the basis of the project scoring.

The assessment criteria are specified in the open calls. They shall clearly relate to the content assessment of the application, and may include, inter alia, the following elements:

• Relevance of the project to the needs of direct and indirect target groups. 
• Coherence between the project and the selected programme output(s), outcome, and objective (the relevant sections of the programme results framework must be published as part of the call text).
• Coherence between the proposed activities to the selected programme output(s).
• Feasibility of the suggested activities. 
• Experience of applicant and capacity to implement the project.
• Sustainability of the project.
• Value for money with reasonable and justifiable budget, and coherence with the proposed activities.

The call text should indicate the achievable maximum total score, and it is recommended that the Fund Operator includes in the call text the minimum total score a project application needs to meet to be recommendable for funding. 

The Fund Operator may wish to consider giving preference to applications that meet certain concerns that are deemed important to achieve the outcome and outputs of the call. This must be made clear in the call text and could for example take the form of additional points for applications from rural areas, specific target groups, minorities, thematic areas that are underrepresented etc. 

Example of a project scoring sheet

In this example, an application receiving less than 48 points should be rejected, regardless whether there would be still be funds available within the call. Furthermore, any application that would receive more than 48 points, but would fail to comply with one of the eliminating criterion (e.g. receive less than 10 for relevance) would also be rejected.

The minimum requirements for the selection of organisational grants are included in the Programme Implementation Agreement.

12.3 Assessment

Project selection procedures should be described in the Management and Control Systems description.

Review of administrative and eligibility criteria

After the deadline for submission of applications, the Fund Operator first reviews the applications for compliance with administrative and eligibility criteria. The Fund Operator should assess these criteria against the published requirements. 

The Fund Operator documents its review for all applications and indicates whether the applicant has fulfilled or not fulfilled the criteria in question. 

It is expected that the Fund Operator establishes a clear and transparent system to record the decision related to the administrative and eligibility checks performed.  

In case any of the criteria is subject to clarification (request for additional information) in line with the published requirements, it should be indicated whether a clarification request has been issued, and the result of such clarification should be recorded. To comply with the principle of equal treatment, the Fund Operator should ensure that equal cases are treated equally when it comes to clarification and asking for additional information from applicants.

Always document the administrative and eligibility assessment of all applications.

Following the completion of the administrative and eligibility review, applicants whose applications are rejected shall be informed of the reasons for the rejection and given a reasonable time to appeal that decision. 

Assessment of project applications by impartial experts

Each project application that meets the administrative and eligibility criteria shall be scored by (at least) two impartial experts appointed by the Fund Operator. Impartial shall not be mistaken for independent. Impartiality means that the expert involved has no direct or indirect interest regarding the project application in question. 

At least one expert shall be independent of the Fund Operator.

Question: Will the Fund Operator be able to use some of its onboard staff as experts for assessment of the content of the project applications?

Answer: Yes. In accordance with Article 7.5.2 of the Programme Implementation Agreement template “Each project application (….) shall be scored by at least two impartial experts appointed by the Fund Operator. At least one expert shall be independent of the Fund Operator.” 

The Fund Operator should ensure that the experts involved in the assessment and scoring of projects possess  the necessary knowledge and expertise to assess the applications.  The Fund Operator can decide to select the experts either through an open call for tender, or invite them on the basis of previous experience, either in CSOs funding work or relevant work with regranting agencies, ministries or other funding institutions etc. as long as the selection is carried out in a clear and transparent manner. 

Regardless of how the experts are selected, it is strongly advised that the Fund Operator organises training(s) for the experts, to familiarise them with the call for proposals, the Programme objective, and to provide them with guidance on the award criteria published in the call for proposals. The Fund Operator should take all reasonable and proportionate measures in order to ensure a transparent, objective, consistent and coherent assessment of the applications.

All experts should sign a declaration of conflict of interest to ensure the prevention of a conflict-of-interest-situation.

The Programme Implementation Agreement provides flexibility for the Fund Operator to develop the details of how the experts conduct their assessment as long as they carry out the assessment in an independent way and in accordance with the selection criteria published in the call for proposals. The method developed by the Fund Operator should be clear, transparent and comply with the general rules and principles of the selection procedure as describe above. 

Example of possible elements of an expert meeting minutes:

  * listing the names of attendees (in each separate discussion group, if relevant)
    *  detailing the key discussion points (in each discussion group, if relevant)
    *  detailing changes made in scores, disclosing the reasons for changes made 
    *  highlighting any measures that were in place for preventing conflicts of interest e.g. by indicating 
        whether experts left the room when they were in a conflict of interest situation
    * Demonstrating that the experts agreed with the final scores by having them sign the minutes of the 
        discussion meetings

The independent scoring does not exclude the possibility for the Fund Operator to organise discussion meetings with the experts to ensure that they carry out the assessment according to guidance provided by the Fund Operator, and that the scores provided are consistent and in line with the criteria published in the call for proposals. The experts can also discuss, meet, consult the Fund Operator if needed for advice on certain aspects, but they cannot be influenced by anyone and should decide on the scores and assessment to their best judgement and independently.  The experts should document and justify their assessment. The Fund Operator should document the main steps of the selection procedure such as the results of meetings of experts or consultations with the Fund Operator. 

In line with the flexibility provided, the Fund Operator is entrusted with finding a method of review for scores where the difference is more than 30% of the higher score. The method can allow e.g. for the experts to meet (with or without the Fund Operator) and discuss their assessments or commissioning a third expert. 

Always document the scoring and assessment of external experts! 

12.4 Selection Committee

The Fund Operator is responsible for establishing at least one Selection Committee that recommend projects to be funded. The role of the Selection Committee is to recommend to the Fund Operator which projects should be funded.  

Selection Committee members

The Fund Operator can, according to needs, establish one or several selection committees. 

The Selection Committee must consist of at least three voting members possessing the relevant expertise, one of whom is external to the Fund Operator. If a selection committee has more than three voting members, the number of external members should preferably be proportionate to the size of the committee. The composition of the selection committee could also take into considerations the substitution of members in the event that a member (or members) must withdraw due to a declaration of conflict of interest.

The selection committee includes observers. The FMO and Embassies of the Donor States covering the Beneficiary State should be invited to participate in the meetings of the Selection Committee as observers. Where they are present, and interpretation is not provided, the meeting shall be conducted in English. There is no limitation on the number of the observers.

Selection Committee meetings 

The selection committee(s) shall operate in an open, transparent and accountable manner, and its composition shall ensure that due attention is paid to possible areas of conflict of interest. All members of the selection committee (both voting members and observers) shall sign a declaration of no conflict of interest. A declaration of conflict of interest does not necessarily need to result in the withdrawal of the selection committee member. The gravity of the conflict of interest situation and its effect on the selection procedure should be assessed by the Fund Operator based on previously established methods and criteria. 

In order for the selection committee members to be well-prepared, and be able to sign a no conflict of interest declaration with full confidence, it is recommended that the ranking list of project applications including the name of the applicants and their average score are circulated to all those attending the selection committee meetings within reasonable time before the meeting. The list should preferably also include the scores provided by the experts with a short description of the project and a summary of comments provided by the experts. 

The selection committee shall review the ranked list of project applications. When reviewing the ranked list of projects, the selection committee shall consider how the totality of projects selected for funding aligns with inter alia the objective, outcomes and outputs of the Fund, country specific focus areas and fund specifics.  

The selection committee has the authority to reject highly ranked projects and to approve lower-ranked projects, provided they meet the minimum score threshold. All such decisions must be justified and documented in the meeting minutes of the selection committee. 

It is recommended that the selection committee establishes statutes/rules of procedure, to define, as a minimum, the methods followed to select projects for funding.

The selection committee may decide to approve a project application with conditions. 

These conditions could relate to modifying the budget, obtaining clarification on some elements of the application etc. The selection committee minutes shall clearly reflect the justification for applying a condition, and the opinion of the members in this regard. 

The selection committee may also decide to establish a reserve list, including project applications that are recommended for support, but due to lack of funding cannot be supported at the time of the decision. The selection committee minutes shall clearly state whether a reserve list has been established, including the list of applications on the reserve list. 

Experts can be invited to the meeting of the selection committee, to provide explanations of their scoring, their overall assessment of the project, and to answer any questions that the members of the selection committee might have. If the experts are invited to the meeting, this should be clearly reflected in the minutes of the meeting. The experts shall in no way influence the selection committee members in their decisions, and should limit themselves to information already provided during their assessment and to clarifications requested by the selection committee.  

Selection Committee meeting minutes

The Selection Committee is required to keep minutes of its meetings. The minutes should provide enough detail to demonstrate that the requirements of the Programme Implementation Agreement have been met and the committee has operated in an open, transparent and accountable manner. 

The formal approval of the selection committee minutes should be documented (e.g. by the members signing the minutes). The Fund Operator shall upload the minutes in English to GrACE not later than a month after each meeting. 

Example of minimum elements of a selection committee meeting minutes:

* The names of the voting election committee members, and the organisations they represent;
* The name of the observer selection committee members, and the organisations they represent;
* A list of any experts present at the meeting, if relevant;
* The name of the chairperson;
* Votes of the members on each project application; the minutes should clearly indicate cases where the members have conflicting opinions on approving or rejecting an application;
* Demonstrating that conflict of interest procedures were dealt with appropriately, and specifying the measures taken;
* Total number of project applications received, how many were rejected for administrative reasons (and very brief summary of reasons overall), how many rejections because of eligibility (and very brief summary of reasons for rejection), total selected projects, total euro amount allocated to them;
* Where the selection committee decides to modify the ranking list, information should be provided on the justification;
* Information on the reserve list and conditionally approved project.

12.5 Decision by the Fund Operator

The Steering Committee of the Fund Operator shall take the final decision regarding which projects to support. It may modify the decision of the Selection Committee in justified cases. Upon request, the FMO shall be invited to observe the meetings of the Steering Committee where decisions on project selection are taken.

The Steering Committee, based on the recommendation of the selection committee, makes a decision on which projects shall be supported. It may modify the decision of the selection committee in justified cases.

In line with the general rules the decision shall be documented, in particular if the decision does not fully reflect the recommendations of the selection committee.

All members of the steering committee shall sign a declaration of no conflict of interest. A declaration of conflict of interest does not necessarily need to result in the withdrawal of the selection committee member. The gravity of the conflict of interest situation and its effect on the selection procedure should be assessed by the Fund Operator based on previously established methods and criteria.

Steering Committee refers to the people appointed to provide high level guidance and strategic direction for the consortium itself. The members can be the same or different than the statutory board members of the consortium organisation. The members of the Steering Committee are considered key personnel in accordance with Article 1.9.5 of the Programme Implementation Agreement. Therefore, FMO must be informed of any change in the members within 5 working days. It is recommended to provide the reasons and justification for the change and as much information as possible about the new members to enable FMO to assess whether they meet the criteria required for such key personnel (e.g. independence, experience).

Notifying applicants 

Both successful and unsuccessful project applicants shall be informed of the outcome of their application in writing with a confirmation of delivery (by letter or e-mail). Unsuccessful applicants shall be provided with feedback on the reasons why their application was not selected.

12.6 Simplified selection procedures for small projects

A small project is a project receiving a total project grant of EUR 25,000 or less.

A simplified selection procedure may be used for calls for proposals for small projects. Simplification means that the Fund Operator does not have to apply the selection procedures described in the Programme Implementation Agreement and there is no requirement to use a selection committee. 

Irrespective of the simplification applied, the Fund Operator should still ensure that the procedure complies with the general rules and principles set out in the Programme Implementation Agreement and explained in section 9.4.1 of this Manual.

The simplified procedure should be agreed with the FMO and described in Annex II to the Programme Implementation Agreement. 

The general principles and rules apply for simplified selection procedures.

Example of a simplified selection procedure: 

The Fund Operator launches a rolling call for proposals for the selection of small projects on information integrity at local level. The call makes available EUR 200 000 and the grant amounts are between EUR 10,000 and 25,000. The Fund Operator decides to prepare a simplified call and application procedure. The call is managed by the consortium member with experience in outreach in rural areas.

The call is launched at the beginning of the year and remains open until the end of the year or until funds are spent. The application form consists of a simplified questionnaire and a few eligibility questions to be answered by the applicant. No supporting documentation are required. The consortium partner organisation’s staff assess the applications as they are received on a first-come, first-served basis, using a checklist published with the open calls. Applications that pass the checklist are invited to a short online interview. The two project assessors recommend the projects to be funded or rejected to a designated senior staff member of the programme, such as the Programme Director, who then reviews the recommendation and makes the final decision. The selection committee and the Fund Operator’s Steering Committee are not involved in the decision-making process. The selection procedure, including notification of the applicant, takes approximately one month from the submission of the application.

As set out in the general rules and principles of the selection procedures, all assessments and decisions are documented and archived, including the staff's assessment, the summary of the interview, the recommendation to the Director and the Steering Committee's final decision.

12.7 Project contract

Project contract and desired programme results: 

For each approved project a project contract is to be concluded between the Fund Operator and the Project Promoter. The project contracts with the selected Project Promoters must include a provision that the selected projects report on results achievement. This means reporting against the outcome and output indicators from the programme results framework, as well as the qualitative information required in the Project Level Information (PLI), both for registration and final reporting. Project contracts should state what data is required from Project Promoters, when, and in which format, in line with the data collection system established by the Fund Operator. Indicators should be referenced in project contracts, and responsibilities for data collection and quality control should be clearly assigned.

A project contract shall be concluded between the Fund Operator and the project promoter for each approved project. The project contract sets out the terms and conditions of grant assistance as well as the roles and responsibilities of the parties. It shall include provisions that ensure that the project promoter takes on any obligations that are necessary for the Fund Operator to comply with its obligations under the Programme Implementation Agreement.

Question: What would constitute the project contract if a pre-defined project is implemented by the Fund Operator?

Answer: The Fund Operator should ensure that all projects are bound by the rules for projects contained in the Programme Implementation Agreement. If the pre-defined project is managed by the Fund Operator, the Programme Implementation Agreement will include the details of the pre-defined project. The Fund Operator shall provide further details during the drafting of the Programme Implementation Agreement on how it will ensure separating roles and functions of the management of the pre-defined project from the Fund Operator role. A good practice is to define the rules for the project in a project rules document adopted by the Steering Committee.

Article 7.6.2 in the Programme Implementation Agreement includes the minimum requirements for the content of the project contract and Article 7.6.4 includes the additional provisions required in case of organisational grants. The project contract shall be drafted by the Fund Operator. The Fund Operator can request the FMO to confirm that the project contract complies with the provisions of the Programme Implementation Agreement.

If a project is implemented in a partnership, the project promoter shall sign a partnership agreement with each of the project partners. The partnership agreement shall detail the roles and responsibilities of each partner in line with the provisions of the Programme Implementation Agreement. The draft partnership agreement shall be submitted to the Fund Operator before the signing of the project contract. The Fund Operator shall verify that the partnership agreement complies with the Programme Implementation Agreement.