Conflicts of Interest Policy

1. Declaration#

• Annual written declaration from every director and every member of staff in a procurement, hiring or finance role.
• Ad-hoc declaration before any meeting where a conflict arises.
• Public-facing register of director conflicts maintained at Companies House where required.

2. Management#

Conflicted person recuses from the relevant decision and the recusal is minuted. For material conflicts, the conflicted director seeks board approval under s.175 Companies Act 2006.

3. Conflicts register#

Maintained by the Company Secretary. Reviewed quarterly by the Audit Committee. Material declarations referenced in board minutes.

4. Examples (non-exhaustive)#

• Personal financial interest in a counterparty.
• Family relationship with a candidate, supplier or competitor.
• Outside directorship in a related sector.
• Significant gift or hospitality (per Anti-Bribery thresholds).

5. Cross-references#

• Anti-Bribery Policy - gifts & hospitality thresholds.
• Whistleblowing Policy - confidential channel for unresolved concerns.
• Board Charter - s.175 Companies Act 2006 board approval route.

6. Review & ownership#

Owner: Company Secretary. Reviewed annually.