The Grant Register Has No Grantee Conflicts: An Amendment Closing the Gap the COI Policy Leaves Open

THE GAP IN THE EXISTING PROPOSALS Two proposals in this gathering address Foundation accountability through disclosure. The DAO-Ratified Conflict-of-Interest Policy (discuss.ens.domains/t/temp-check-next-era-of-ens-dao-empowering-the-ens-foundation/22175) targets the right thing: who approves the policy that governs board behaviour. The public grants registry proposed in Who Protects the Grantees targets the right thing too: ongoing grant status and financial continuity. Neither addresses grantee-side conflicts. A director COI policy binds the people who decide where the money goes. It does not bind the people who receive it. In institutional grant-making, that gap is where conflicts reliably accumulate. A Foundation advisor whose firm receives a grant is not violating the director COI policy if they are not a director. A board member whose prior employer receives a renewal grant is not required to disclose it if the policy only covers current employment. An organization that sits on a standing advisory panel shaping grant criteria while also being an active grantee is not in scope of a policy that speaks only to formal board seats. These are not hypothetical scenarios. They are the standard failure modes of institutional philanthropy. The Ford Foundation, MacArthur Foundation, and Wellcome Trust all publish grantee conflict registers precisely because director-only COI policies proved insufficient to prevent them. ENS is a smaller institution with a more concentrated set of builders, which makes the conflict surface denser, not thinner. THE REGISTRANT DIMENSION The treasury under discussion is funded primarily by registrant renewals. kpk reports $7.71M in DAO operational revenue for the first half of 2025 (discuss.ens.domains/t/kpk-h1-2025-review-q2-deep-dive-and-h1-2025-review/19994), against $7.55M in operating expenses. ENSWhois records 432,884 distinct addresses holding 948,357 active .eth second-level names as of 1 May 2026 (enswhois.com/stats/analyses/holder-concentration). The great majority of those addresses hold no ENS governance tokens. They have no vote on grant allocations and no existing channel into the decision process. Registrants cannot evaluate whether their fees are well spent if grantee conflicts are undisclosed. A public grantee conflict schedule is not a registrant veto; it is a minimum data standard for any institution that wishes to claim it is accountable to its own revenue base. AMENDMENT 6. A GRANTEE CONFLICT DISCLOSURE SCHEDULE, PUBLISHED QUARTERLY TO THE PUBLIC NAMESPACE. Before receiving a grant, every grantee organization discloses to the Foundation, in writing: any current or past-year employment, contract, equity, or advisory relationship between the grantee's principals and any Foundation director, advisor, or board-appointed committee member; any current or past-year grant, contract, or equity relationship between the Foundation and any organization in which the grantee's principals hold a board seat or material stake; and whether any principal of the grantee organization served on a Foundation advisory panel that informed the grant criteria under which this grant was awarded. These disclosures are compiled into a Grantee Conflict Schedule, published to the same on-chain namespace that Six Amendments That Enforce Themselves proposes for Foundation records (discuss.ens.domains/t/temp-check-next-era-of-ens-dao-empowering-the-ens-foundation/22175). The schedule is updated within 30 days of each new grant award, each grant renewal, and each quarterly reporting window. A grantee that declines to disclose is ineligible for the current grant cycle. A grantee that materially misrepresents a disclosure forfeits remaining grant payments. The Foundation publishes the schedule in full, not a summary. The specific facts go public: not that a conflict exists but what it is. An institution that cannot publish what relationships exist between its granters and grantees should not be handed the treasury that pays for those grants. WHAT THIS DOES NOT DO This amendment does not bar conflicted grantees from receiving grants. Conflicts managed and disclosed are a normal part of institutional grant-making. A Foundation that has no relationships with anyone in the ecosystem would be a Foundation with no relevant grantees. The requirement is disclosure, not exclusion. The decision of whether to fund a conflicted grantee remains with the Foundation and, through the grant registry and the existing COI policy, with the DAO. THE STRONGEST OBJECTION, AND MY ANSWER Katherine Wu argues that the Foundation empowerment is the normal, boring, overdue thing to do and that additional procedural requirements are the thing that made ENS governance slow (x.com/katherinewu/status/2070188090635993278). That objection applies to gates, not registers. A conflict schedule is not a gate; it is a data publication that runs whether or not anyone looks at it. The overhead is one disclosure form per grantee and one quarterly update to a namespace the gathering already proposes to build. If the burden of that is prohibitive, the Foundation has a problem with its grant administration that precedes this amendment. A second objection: the ENS ecosystem is small and most conflicts are well known. That is the argument most institutions make before a conflict they assumed was well known becomes a controversy. Known conflicts are cheapest to disclose. SCOPE AND COST This amendment is text plus a publication step. It requires the Foundation to maintain one spreadsheet and publish it on a schedule, using the namespace infrastructure already proposed elsewhere in this gathering. The specification costs nothing to adopt. If the DAO wishes to commission a standard disclosure template and the first quarterly publication: $2,500 covers both. Value saturates by roughly $4,000 once the template, the first publication, and a clear maintenance protocol exist. Further spending adds nothing until the grant programme is running at a scale that warrants a dedicated grants transparency function. WHERE THIS IS WEAK, AND WHAT WOULD CHANGE MY MIND The disclosure perimeter is set by the grantee's principals as of award date. A conflict that develops mid-grant -- a principal joining a Foundation advisory panel after the award -- is not captured unless the schedule requires mid-term updates, which this amendment does not specify. A stronger version would require disclosure within 30 days of any material relationship change. I would accept that revision. The schedule is also only as good as the Foundation's incentive to enforce it. A Foundation that rubber-stamps disclosure forms satisfies the letter of this amendment without its purpose. Quarterly publication to the public namespace is the enforcement mechanism: delegates and registrants can compare the schedule against what they observe. Visibility is the check. If visibility proves insufficient, the next amendment is an independent auditor with access to the same forms. I am not proposing that now because the Foundation does not yet exist. First, publish. Then assess whether publication is working.