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Introduction to this document

Conflicts of interest policy

A conflicts of interest policy will assist with ensuring good governance and with preventing fraud and corruption.

Conflicts of interest explanation

Our Conflicts of Interest Policy starts by explaining to your employees what a conflict of interest is and when one might arise. As our policy is also intended to be part of your suite of other policies and contractual provisions aimed at ensuring best practice in your business when it comes to good corporate governance and preventing fraud and corruption, we’ve stated that it should be read in conjunction with those relevant policies and provisions, such as those related to anti-bribery, gifts from clients/suppliers, outside business interests and whistleblowing. You’ll need to amend or add to our list as appropriate to your own suite of policies and provisions.

Conduct expectations

Our policy then sets out a number of conduct expectations for the employee, all aimed at avoiding any conflicts of interest arising between them and your business, including at all times (1) acting in the best interests of your business; (2) maintaining high standards of integrity, professionalism, impartiality and objectivity in all their relationships, dealings and decisions related to your business; (3) not using their position for personal gain; and (4) not engaging in any transactions on your behalf with businesses or individuals in which or with whom they have an interest.

Disclosure requirements

Our policy finally requires the employee not only to immediately disclose actual, potential or perceived conflicts of interest to their line manager but also to immediately disclose such matters as serious breaches of duty, bribery and the criminal facilitation of tax evasion (whether engaged in by them or by another employee or officer). We’ve covered perceived conflicts of interest as well as actual and potential ones because, while there may not actually be anything improper taking place, at least you can then take that decision once the disclosure has taken place. It’s your choice whether you want to maintain a register of conflicts of interest or to record any conflicts disclosures in another way, subject to compliance with data protection requirements.