Conflict of Interest Policy

1. Purpose
The purpose of this Conflict of Interest Policy is to protect the interests of the ATT by ensuring that decisions made by Council members and volunteers are not influenced by personal interests and to comply with Charity Commission Guidelines. This policy is intended to supplement but not replace any applicable laws governing conflict of interest in charities.

2. Definition of Conflict of Interest
A conflict of interest arises when an individual’s personal interests, relationships, or outside activities influence, or could be perceived to influence, their decision-making within the charity. This includes any situation where an individual might benefit personally, whether financially or otherwise, from decisions they make in their role within the charity.

3. Scope
This policy applies to all Council members and volunteers of the charity.

4. Identifying Conflicts of Interest
Conflicts of interest may occur in various situations, including but not limited to:

  • Financial interests: When a person benefits financially from decisions made by the charity.
  • Personal relationships: When a person’s family member, friend, or business associate is involved in a decision made by the charity.
  • External commitments: When a person has commitments or interests outside the charity that may interfere with their ability to act in the charity’s best interests.

 

5. Duty to Disclose
All Council members and volunteers have a duty to disclose any potential or actual conflicts of interest. Disclosures should be made in writing to the Chief Executive and/or declared at the start of the meeting which they are attending.

If an individual is uncertain whether they are conflicted, they should err on the side of caution and make a declaration.

6. Procedures for Managing Conflicts of Interest
    a. Disclosure
       1. Initial Disclosure: Upon joining the ATT, Council members and volunteers must complete a conflict of interest disclosure form.
       This records any conflicts which need to be declared at every meeting they attend. 
       2. Ongoing Disclosure: Individuals must promptly disclose any new conflicts of interest as they arise.
       This is a standing item on every Council, Committee, and Steering Group agenda.

   b. Evaluation
       1. Review: The Chief Executive will review all disclosures. These will also be reviewed by the Auditors during the Annual audit process.

    c. Recusal
       1. Participation: The individual with the conflict of interest will not participate in discussions or decisions related to the matter
       They will either be asked to remain silent in any discussions or to leave the room (virtual or physical).
       2. Minutes: The minutes of the meeting will record the disclosure and the individual’s recusal.

7. Documentation 
All disclosures, discussions, and decisions related to conflicts of interest will be documented in the minutes of the Council, Committee or Steering Group meetings.

8. Annual Review 
This policy will be reviewed annually by Council to ensure it remains effective and in line with legal requirements and best practices.

9. Compliance 
Failure to comply with this policy may result in termination of the individual’s relationship with the charity.

By adhering to this Conflict of Interest Policy, the ATT aims to maintain integrity, transparency, and accountability in all its operations, ensuring that decisions are made in the best interests of the charity.