Why we have a Conflict of Interest Policy

All staff, volunteers and Trustees will strive to avoid conflict of interest between the interests of the Organisation on the one hand, and personal, professional, and business interests on the other. This includes avoiding actual conflicts of interest as well as the perception of conflicts of interest.

Trustees have a legal obligation to act in the best interests of the National Paralympic Heritage Trust and in accordance with the National Paralympic Heritage Trust governing document and Data Protection Policy to avoid situations where there may be a potential conflict of interest.

Conflicts of interests may arise where an individual’s personal or family interests and/or loyalties conflict with those of the Trust.

Such conflicts may create problems; they can:

• discourage free discussion
• result in decisions or actions that are not in the interests of the Trust; and risk the impression that the Trust has acted improperly.

The aim of this policy is to protect both the Trust and the individuals involved from any appearance of impropriety.

The Declaration of Interests

We ask staff, volunteers and Trustees to declare their interests, and any gifts or significant hospitality received in connection with their role in the National Paralympic Heritage Trust. A declaration of interest form is provided for this purpose.

The declaration of interests needs to be updated at least annually and also when any changes occur.

The following types of interest should be declared:

• Any personal/family relationships with paid staff and volunteers or possible recruitment of any personal or family member.
• Any gifts or hospitality received.
• A Trustee renting property
• A Trustee lending money to the charity.
• Any relationships with other groups that will affect your role as Trustee – if you are a member of another organisation this needs to be declared as there may be a conflict. Particularly if both organisations work in the same geographical area or have the same client / user groups.
• You are a councillor, employee or board member of an organisation that the National Paralympic Heritage Trust may approach for funding or who is currently providing funding for the Trust.
• A trustee learns of an opportunity at a board meeting which the charity may or may not wish to exploit but which he / she wishes to take advantage of themselves or on behalf of another group.
• Where a Trustee works for or represents an entity which supplies services/goods to the NPHT (whether for remuneration or not).
   

Data Protection

The information provided will be processed in accordance with data protection laws and principles as set out in the Data Protection Policy. Data will be processed only to ensure that Trustees act in the best interests of the National Paralympic Heritage Trust. The information provided will not be used for any other purpose.

What to do if you face a Conflict of Interest

If there is a situation that will be a long-term conflict this should be discussed with other Trustees (in particular the Chair) at the earliest possibility and a decision made on how to proceed.

At the beginning of all meetings you should declare immediately if there is an item on the agenda where there may be a conflict of interest.

You should declare your interest at the earliest opportunity and withdraw from any subsequent discussion. You may, however, participate in discussions from which you may indirectly benefit, for example where the benefits are universal to all users, or where your benefit is minimal. So long as the situation is fully understood by all members taking part in the discussion.

Disclosure in Accounts

Any benefits a Trustee receives from the National Paralympic Heritage Trust in the course of an accounting year must be disclosed.

Where a member of the National Paralympic Heritage Trust staff is connected to a party involved in the supply of a service or product to the charity, this information will also be fully disclosed in the annual report and accounts.

Decisions taken where a Trustee or Member of Staff has an Interest

In the event of the board having to decide upon a question in which a Trustee or member of staff has an interest, all decisions will be made by vote, in line with the organisation’s constitution.

The Trustee, Member or member of staff in question should recuse themselves from the debate and not vote on the issue.

Recording Disclosure of Interest

All decision, including the declared conflict and the outcome should be reported in the minutes of the meeting.

All Trustees are required to update their Conflict of Interest on an annual basis.

Dated: May 2018

Reviewed: August 2020

Next review date: August 2022