Conflicts of Interest Policy
iungo Solutions Limited (“iungo”) is a digitally native organisation operating in the areas of technology creation, policy development, and human resource consulting. We are a proud Welsh business providing meaningful and empowering employment for people across the four nations.
The core principle of this policy is to set out the philosophies which we use to identify, manage, and mitigate conflicts of interest.
Scope of Policy
The scope of this Policy applies to employees, contractors, and volunteers, collectively referred to as “representatives”.
In the context of this Policy, a conflict of interest is a situation in which the concerns or aims of the iungo representative are incompatible with that of iungo Solutions. There are four levels for a conflict of interest:
- Perceived conflict of interest – the interests of the representative could be perceived to conflict with those of the company.
- Potential conflict of interest – the interests of the representative could conflict with those of the company.
- Actual conflict of interest – the interests of the representative do conflict with those of the company, but the severity of impact may not be significant.
- Material conflict of interest – the interests of the representative do conflict with those of the company, and the severity of impact may not be significant.
Conflict of Interest types
External interests and affiliations
iungo Solutions places no universal restriction on representatives wishing to carry on business interests externally. However, they may not place themselves in a position in which your personal or professional interests might reasonably be seen to conflict with those of iungo.
Where a representative is related to or has a close relationship with an employee, contractor, volunteer, learner, customer, supplier, or competitor, they are reminded to
treat confidential information in a sensitive manner. If they, or their line manager, has a concern about the relationship they should discuss this with the Human Resources Officer.
To protect iungo and its representatives in this situation, the Policy mandates that:
- No representative should work with, or under the direct supervision of someone who is either a relative or a person with whom they share a close relationship.
- No representative should be involved in matters relating to compensation or expenses payments for someone who is either a relative or a person with whom they share a close relationship.
- No representative should be involved in the tutoring or assessment of a learners work if the learner is a relative or someone with whom they share a close relationship.
- Wherever possible, no representative should be placed in a position where they have access to privileged or confidential information about a relative or someone with whom they have a close personal relationship.
Representatives should consider the implications of accepting gifts from organisations or individuals with whom they have a business relationship on iungo’s behalf.
iungo advises that representatives should not accept gifts above a nominal value, as this may be perceived as a conflict of interest or could even be interpreted as a bribe.
If gifts are accepted, the item description, value, supplier, and date of receipt should be provided in writing to email@example.com.
Declaring and Managing conflicts of interest
All new employees, contractors and volunteers are required to declare potential and actual conflicts of interest during the onboarding process. Declarations will be updated annually but if a new conflict arises in that period, the iungo representative should declare that conflict as follows:
- discuss with their line manager any relationships which might reasonably be perceived as a conflict of interest with iungo.
- declare potential conflicts of interest in writing to firstname.lastname@example.org immediately as they arise.
If a representative declares, or iungo determines in its reasonable judgement, a business interest or external affiliation that amounts to an actual conflict of interest, immediate action will be taken to mitigate or eliminate the conflict.
If, in the reasonable judgment of iungo, such conflict poses a serious material conflict to and with the performance of representative’s obligations under their contract, then iungo may terminate the contract immediately upon written notice to representative.
Conflicts that are not declared could result in disciplinary action. All investigations will be carried out as per the Disciplinary and Grievance Procedure.
External reporting of conflicts
Conflicts of interest involving a learner’s assessment must be reported immediately to the Awarding Organisation.
Where there is a concern of criminal activity, conflicts of interest should be reported to the relevant authorities for investigation.
The Executive Chair will be responsible for:
- Ensuring that the Policy is reviewed at least annually, or upon an update to the regulatory framework, and appropriate advice is given on content.
- Approving the Policy and seeking reassurance from the Chief Executive that it is being implemented correctly.
The Chief Executive will be responsible for:
- Establishing a culture that is open, transparent, and proactive in managing conflicts of interest.
- Developing effective governance arrangements and ensuring that relevant policies, procedures, and training are in place across the organisation.
- Reviewing this Policy and the attached procedures.
- Ensuring sufficient resources are in place to conduct the duties outlined.
- Ensuring that employees, contractors, and volunteers understand and feel equipped to discharge their responsibilities under this policy.
Employees, contractors, and volunteers are responsible for:
- Behaving in accordance with the Policy and associated procedures and informing their line managers of any activity contrary to the principles outlined.
- Attending relevant training and CPD events.
Learners are responsible for:
- Making their tutor or assessor aware of any accessibility difficulties, special considerations or reasonable adjustments required.
Review and Sign-off
This Policy is subject to 12-month review. The next review is due on 01 November 2024.
|Name:||Tom de Vall|
|Signature:||T. de Vall|
|Date:||01 November 2023|