Conflict of Interest Policy
Oldham Enterprise Trust (OET) Registered Charity No. 1172213
Conflict of Interest Policy
- Policy Statement
Oldham Enterprise Trust (OET) is committed to maintaining the highest standards of integrity, transparency, and accountability in all its activities. Trustees and those acting on behalf of OET must act solely in the best interests of the charity and avoid situations where personal, professional, or financial interests could conflict with their duties.
This policy is designed to protect the charity, its trustees, staff, volunteers, and stakeholders by ensuring that conflicts of interest are identified, declared, and managed appropriately.
- Legal Framework
This policy is informed by the Charities Act 2011 and Charity Commission guidance on trustee duties. Trustees have a legal duty to:
- Act only in the best interests of the charity
- Avoid conflicts of interest
- Not receive unauthorised benefits
- Declare any personal interest that may conflict with the charity’s interests
- Scope
This policy applies to:
- Trustees
- Members of advisory panels or committees
- Staff and volunteers
- Contractors or partners involved in decision-making
- Definition of a Conflict of Interest
A conflict of interest arises where an individual’s personal, professional, or financial interests could influence, or be perceived to influence, their decision-making on behalf of OET.
Conflicts may be:
- Actual – a direct conflict exists
- Potential – circumstances could develop into a conflict
- Perceived – others may reasonably believe a conflict exists
Examples include:
- A trustee related to a funding applicant
- A trustee with financial interest in a supplier
- A trustee connected to a partner organisation
- A trustee applying for paid work with OET
- Declaration of Interests
All trustees must:
- Complete a written declaration of interests upon appointment
- Update their declaration annually
- Declare any new interests as they arise
A Register of Interests will be maintained and reviewed annually by the Board.
- Managing Conflicts at Meetings
At the start of each board or committee meeting, members will be asked to declare any conflicts relating to agenda items.
Where a conflict exists:
- The individual must withdraw from discussion and decision-making on that item
- The withdrawal will be recorded in the minutes
- The remaining trustees will determine how the matter proceeds
If the Chair has a conflict, another Trustee will oversee that item.
- Record Keeping
All declared conflicts and actions taken will be clearly recorded in meeting minutes. The Register of Interests will be stored securely and reviewed annually.
- Failure to Declare
Failure to declare a relevant conflict may be treated as a breach of trustee duty and may result in appropriate action, including potential removal from office in accordance with the governing document.
- Review
This policy will be reviewed annually by the Board of Trustees.