Conflict of Interest Policy Template

Conflict of Interest Policy

Purpose of Conflict of Interest Policy

This Conflict of Interest Policy explains [Company Name] expectations for employees, officers and contractors to identify, disclose and manage actual, potential and perceived conflicts between personal interests and the interests of the organisation. The policy exists to protect impartial decision making, maintain trust with clients and partners, and preserve the reputation and integrity of [Company Name].

Scope

This policy applies to all employees, officers, board members, temporary staff and contractors of [Company Name], regardless of role or location. Third parties acting on behalf of [Company Name] are expected to follow equivalent conflict of interest standards when delivering services.

Definitions and Principles

A conflict of interest arises when an individual’s personal, financial or other interests may influence, or appear to influence, their ability to perform duties objectively. Employees must avoid situations that create divided loyalties, fail to protect confidential information, or compromise business decisions.

Examples of Conflicts

• Holding a financial interest in a supplier, customer or competitor that could affect procurement or contract decisions
• Supervising or hiring a family member or close personal associate without disclosing the relationship
• Receiving gifts, favours or hospitality that could influence business choices
• Using company information, assets or opportunities for personal gain

Disclosure Requirements

Employees must promptly disclose actual, potential or perceived conflicts of interest to their line manager and HR in writing when they arise and during annual disclosure processes. The disclosure should include a description of the interest, parties involved and potential impact on duties.

Gifts, Hospitality and Entertainment

Accepting gifts, hospitality or entertainment is permitted only when modest, infrequent and not intended to influence business decisions. Employees must not accept cash or equivalents. Any gift or hospitality that might reasonably be seen to influence decision making must be declared and approved in accordance with the approval process below.

Outside Employment and Business Interests

Employees may undertake outside employment or hold business interests provided the activity does not interfere with job performance, compete with [Company Name], or create a conflict. Prior notification and written approval from the employee’s manager and HR are required when outside activities could overlap with company responsibilities.

Procurement, Vendor Relationships and Third Parties

Employees involved in procurement, vendor selection or contract management must disclose any personal relationships or financial interests with suppliers or bidders. Employees with such relationships must recuse themselves from related decision making and approval processes.

Confidential Information and Use of Company Assets

Employees must protect confidential information and must not use company resources or information for personal benefit. Sharing confidential information with external parties that could advantage personal interests is prohibited.

Recordkeeping and Monitoring

All disclosures, approvals, and recusal notices will be recorded and retained by HR for monitoring and audit purposes. Managers and HR will monitor compliance and may request additional information when necessary to assess a reported conflict.

Approval Process

Employees must submit conflict disclosures in writing to their line manager and HR as soon as they become aware of the issue. The approval process includes:

• Initial review by the manager for completeness and immediate mitigation where needed
• HR assessment of the nature and severity of the conflict and recommendation of appropriate controls
• Written approval, documented mitigation measures or requirement to remove the conflict granted by the manager and HR where appropriate
• Escalation to senior management or the board where conflicts involve senior leaders or critical business risks

Managers are responsible for ensuring disclosures are handled promptly and for enforcing agreed mitigation actions. HR owns the recordkeeping function and provides guidance, training and advice on conflict management.

Non-Compliance

Failure to disclose a conflict of interest, to follow an approved mitigation plan, or to recuse oneself from conflicted decision making may result in corrective action. Consequences may include reassignment of duties, repayment of improper gains, formal disciplinary action up to and including termination of employment, and removal of approvals or privileges.

Note

This policy may be updated periodically to reflect business needs and best practice. Employees are expected to remain aware of the current policy and to raise questions with HR or their manager if they are uncertain whether a situation creates a conflict of interest.

For clarification on how this Conflict of Interest Policy applies to a specific situation, contact HR.