IntegrityFile.org Public Source Research and Due Diligence
Resources/NGO Partner Pages

Partner Selection Due Diligence

Help compliance, grants, procurement, safeguarding, and program teams document partner selection due diligence before choosing among shortlisted partners.

What this check is

Partner Selection Due Diligence is a structured public-source and file-evidence review used before choosing among shortlisted partners. It looks for signals related to comparative public-source review, selection integrity, conflicts, eligibility, and decision rationale. The purpose is not to build a rumor list or to make an instant pass/fail decision; the purpose is to help a reviewer record what was checked, what was found, how reliable the source appears to be, and what decision or control followed.

A high-quality page should teach the reader a defensible workflow: define the exact entity, search the right names and jurisdictions, compare public records with internal documents, record source dates, preserve evidence, and escalate only when the signal is relevant and match confidence is reasonable. This approach is especially important for NGOs and civil society organizations because names, acronyms, language variants, fiscal sponsorship, coalitions, and informal operating histories can make shallow searches misleading.

In a due diligence file, this check should produce a short evidence trail: entity identifiers, people reviewed, jurisdictions searched, source links, search terms, screenshots or extracts where allowed, reviewer notes, partner explanations, unresolved questions, and any conditions placed on approval. A clean search should still be documented, because future reviewers need to know what was searched and when.

When to run it

  • after a shortlist is created but before award, public announcement, or negotiation of binding terms
  • before naming a partner in a proposal, consortium application, or donor submission
  • when selection could be challenged by another applicant, donor, board member, community stakeholder, or auditor
  • when selection relies on sole-source, urgent response, community access, or unique technical capacity

Run the check early enough that findings can still affect selection, award structure, budget controls, reporting duties, monitoring plans, or the decision not to proceed. It should also be refreshed when time has passed, risk context has changed, a new country or donor is added, key people change, or the partner will take on a role that is more sensitive than originally planned.

What to look for

  • the shortlist, selection criteria, evaluators, conflict disclosures, and decision authority
  • comparable baseline searches across candidates: legal identity, key people, sanctions/debarment, public allegations, and eligibility
  • public signals that could affect eligibility, neutrality, community acceptance, fiscal controls, or donor confidence
  • why a selected partner is acceptable and why other technically strong candidates were not selected
  • Name-variant accuracy: legal name, acronym, translated name, local-script name, former names, trading names, coalition names, and names used by fiscal sponsors or affiliates.
  • Match confidence: whether the public record relates to the same entity or person, using identifiers such as address, registration number, officer name, website, tax number, geography, and date.
  • Risk status: whether a signal is current, resolved, disputed, corrected, historical, jurisdiction-limited, or linked to a different entity with a similar name.
  • Decision relevance: whether the signal affects the specific role, budget, geography, beneficiaries, goods, data, or authority the organization would give to the partner.

Public sources to review

Start with official and primary sources when available. Supplement with credible media, donor pages, court/regulator pages, annual reports, and partner-provided documents. Record access dates, source limitations, search settings, and false-positive logic.

IRS - Tax Exempt Organization SearchUse for U.S. tax-exempt status, Form 990 returns, Pub. 78 data, determination letters, and revocation data. IRS - TEOS applicationUse for searching tax-exempt organization data by EIN or organization name. Charity Commission for England and Wales - Register of charitiesUse for charity status, trustees, finances, and regulatory action in England and Wales. GOV.UK - Search the charity registerUse for charity details, activities, trustees, and financial reports in England and Wales. Companies House - Find and update company informationUse for UK company status, officers, filings, previous names, charges, and insolvency signals. GOV.UK - Get information about a companyUse for company details, previous names, officers, filings, and insolvency information. Canada Revenue Agency - How to get information about a charityUse for Canadian charity status, activities, T3010 information, revocation, suspension, and penalties. ACNC - Charity RegisterUse for Australian charity details, programs, finances, people, and compliance action. OpenCorporates - Company dataUse as a supplemental legal-entity source where official registry access is difficult; do not use as a substitute for official records. SAM.gov - Exclusions searchUse for U.S. exclusions, suspension, and debarment checks where required. eCFR - 2 CFR 180.300 Verification of exclusionsUse for exclusion-check methods when U.S. federal nonprocurement rules apply. U.S. Treasury OFAC - Sanctions List SearchUse for U.S. sanctions list search; record name variants, settings, and false-positive logic. U.S. Treasury OFAC - Sanctions List Service downloadsUse for downloadable OFAC sanctions list data and current list versions. UN Security Council - Consolidated Sanctions ListUse for UN-listed persons and entities. EU Sanctions MapUse for EU restrictive measures and country/regime context. GOV.UK - The UK Sanctions ListUse for current UK designations; the UK Sanctions List is now the current consolidated UK source.

Search terms to use

"[legal name]" "[country]" "[legal name]" NGO registration OR charity register OR company register "[legal name]" audit OR investigation OR complaint OR allegation "[legal name]" fraud OR corruption OR bribery OR "misuse of funds" "[legal name]" sanctions OR debarred OR suspended OR excluded "[director name]" "[organization name]" "[former name]" OR "[local-language name]" "[organization name]" "annual report" OR "financial statements" OR "Form 990" "[candidate name]" "shortlisted" OR "award" OR "grant" "[candidate name]" "conflict of interest" OR "related party" "[candidate name]" "donor" OR "funded by" OR "partner of" "[decision-maker name]" "[candidate name]"

What reviewers often miss

  • checking only the selected partner and not recording baseline checks on other finalists
  • using inconsistent search terms across candidates
  • writing 'no issues found' without sources, dates, terms, or reviewer
  • collecting conflict disclosures after the decision rather than before deliberation
  • Not documenting why a near-match was ruled out, especially for common names, transliterations, and older articles.
  • Relying on a single search engine, a single spelling, or a partner-provided document without checking an official source where one exists.
  • Treating a clean public-source review as a permanent clearance rather than a dated snapshot that may need renewal.
  • Failing to connect the finding to the actual decision: proceed, proceed with controls, pause, reject, report, or investigate.

Expert section: How to document public-source review before final partner selection

The expert issue for this page is how to document public-source review before final partner selection. This is where the reviewer should move beyond generic web searching and show practical judgment: what matters for this specific relationship, which facts are material, which facts are noise, and which controls would actually reduce risk.

  • A defensible file has three layers: selection criteria, public-source review, and decision rationale. The criteria explain what the project needs; the review shows what was checked; the rationale explains why the final decision is reasonable.
  • Shortlisted candidates should receive comparable baseline review unless a documented trigger justifies deeper review for one candidate.
  • Create a compact evidence table with source, search term, result, match confidence, risk significance, and mitigation. This prevents decisions based on rumors or reputation alone.
  • If a partner is named before award, complete public-source review before submission or clearly state that the commitment is conditional.

A strong expert note connects each observation to a file decision. For example, a missing filing may lead to a request for updated registration evidence; a related-party link may lead to recusal; a safeguarding signal may require escalation to the safeguarding lead; a donor audit finding may require repayment status and corrective-action evidence; and a sanctions or debarment match may require immediate legal or donor review.

  • Minimum evidence fields: entity or person searched; exact search term; source; access date; match identifiers; reviewer conclusion; partner response; escalation route; decision; and next review date.
  • Materiality test: does the signal affect funds, authority, beneficiaries, data, goods, field access, public trust, donor obligations, or legal eligibility?
  • Control design: convert findings into specific conditions such as dual authorization, restricted budget lines, enhanced reporting, site verification, training, data-access limits, or approval gates.
  • Uncertainty handling: write down what is unknown, why it could not be confirmed from public sources, and what evidence would resolve it.

What to do when a signal appears

  1. Classify the signal against the page scope: comparative public-source review, selection integrity, conflicts, eligibility, and decision rationale. If it is outside scope, document why it was not material.
  2. Confirm match quality before escalation. Compare names, dates, addresses, registration numbers, people, websites, operating countries, and role descriptions.
  3. Preserve evidence in the file. Save the source title, URL, access date, screenshot or extract where permitted, search term, and reviewer note.
  4. Ask the partner for a targeted explanation and supporting documents, not a broad denial. Give the partner a chance to correct identity mistakes or provide closure evidence.
  5. Escalate according to severity. Sanctions, debarment, safeguarding, credible fraud, criminal, donor-reportable, or legal-status signals should move to the responsible compliance, legal, safeguarding, procurement, grants, or donor lead.
  6. Decide the operating response: clear, clear with explanation, proceed with conditions, pause, reject, report, or investigate.
  7. Set a monitoring trigger. Examples include leadership change, new country, new budget, new donor, new subpartner, new adverse media, open audit, or expired registration.

Realistic review scenarios

  • Two NGOs are shortlisted; one has stronger technical capacity but a lapsed filing. The file conditions selection on updated registry evidence.
  • A staff member recommends a partner led by a former colleague. The file records disclosure, recusal, and independent review.
  • An emergency response requires rapid selection. The file records minimum pre-launch checks and a follow-up review schedule.

For publication, scenarios should read like practical training examples rather than dramatic allegations. They should show how a reviewer identifies a signal, checks match confidence, asks a narrow follow-up question, and records the decision. This helps readers understand that due diligence is a documented decision process, not a search for reasons to reject every partner.

File-ready wording

Clean review wording: On [date], [reviewer] completed partner selection due diligence for [legal entity name] using the entity name, acronym, former names, local-language names, key people, and relevant jurisdictions. No confirmed material public-source signal was identified from the sources reviewed. This conclusion is limited to the sources, search terms, dates, and jurisdictions recorded in the file.

Signal identified wording: On [date], the review identified a public-source signal relating to [describe signal]. Match confidence was assessed as [low/medium/high] because [identifiers]. The partner was asked to provide [specific document or explanation]. The matter was escalated to [team/person] because it may affect [funds/beneficiaries/legal eligibility/donor obligations/public trust].

Proceed-with-conditions wording: Approval may proceed only if [condition] is completed before [milestone], [control] is added to the agreement or monitoring plan, and [owner] confirms closure. The file should be refreshed by [date/event] or earlier if a new signal appears.

Unable-to-confirm wording: Public sources did not allow the reviewer to confirm [fact]. The file should state the limitation, list the sources checked, request partner documentation if needed, and avoid implying that absence of public evidence proves absence of risk.

What this does not replace

  • Legal advice, sanctions counsel, tax advice, charity-law advice, employment advice, or donor-specific eligibility determinations.
  • A financial audit, forensic investigation, site visit, beneficiary interview process, safeguarding investigation, or security assessment.
  • Mandatory donor vetting, government screening, anti-terrorism certification, conflict-of-interest disclosure, procurement approval, or internal risk committee review.
  • Partner capacity assessment, reference checks, program-quality review, environmental and social review, data-protection impact assessment, or ongoing monitoring.
  • A final conclusion that an allegation is true or false. Public-source review documents signals and match confidence; adjudication requires the proper authority and process.

Follow-up questions

  • Which candidates were shortlisted and what sources were searched for each?
  • Were search terms consistent across candidates?
  • Did decision-makers disclose relationships with any candidate?
  • Were any signals material to selection, mitigation, or rejection?
  • Who approved the selection and what evidence did they review?
  • What conditions must be satisfied before signature or public announcement?

Related due diligence guides