The international development community is accustomed to project implementation taking place in-field by local Non-Governmental Organizations. As such, there are certain norms and expectations which have developed over the decades. With increased investment in blended finance models and grant-based incentives being awarded to private-sector entities, it is important to understand some of the major differences between how commercial entities manage ESG (Environmental, Social, Governance) grants as compared to traditional NGO implementation. In our work through INFRONT and other experiences of the Investment Technical Team, we have seen that there are 3 major areas where commercial entities differ from NGOs in this respect.