Purpose
Fivehead Village Hall & Playing Field CIO ("the CIO") is committed to transparency, integrity and good governance. This policy makes sure trustees and volunteers act only in the best interests of the CIO, and avoid situations where personal or outside interests could influence, or appear to influence, their decisions.
It supports the requirements of:
- The Charities Act 2011
- The CIO constitution
- Charity Commission guidance CC29 (Conflicts of interest)
What a conflict of interest is
A conflict of interest arises where a trustee's or volunteer's personal interests, or their duties to another organisation, could influence their decisions or actions on behalf of the CIO. Conflicts may be:
- Actual: the conflict exists now
- Potential: the conflict may arise in future
- Perceived: others may reasonably believe a conflict exists
All three are treated equally seriously.
Examples
Conflicts may include (but are not limited to):
Personal or financial interests
- A trustee's business quoting for hall or field work
- A relative being employed or contracted by the CIO
- A trustee receiving payment for training, supplies or services
Loyalty conflicts
- Being a trustee of another local organisation that uses the hall or field
- Committee membership of local sports groups, clubs or charities
- Decisions involving close friends or family
Reputational or political interests
- Personal campaigns that conflict with the CIO's neutrality
- Using CIO facilities for activities linked to a trustee's outside interests
Use of CIO resources
- Using hall equipment, volunteer time or CIO branding for outside benefit
What trustees and volunteers must do
Everyone covered by this policy must:
- Declare conflicts promptly
- Complete the annual declaration of interests
- Update their declaration when their circumstances change
- Leave discussions where required
- Act only in the CIO's best interests
Trustees have a legal duty to avoid conflicts and to manage them properly when they arise.
Register of interests
The CIO keeps a register of interests covering employment, self-employment and business ownership, trusteeships and directorships, membership of local committees and clubs, contracts with the CIO, and close family connections relevant to CIO business. The register is updated every year, stored securely in SharePoint, and available to trustees on request.
Declaring conflicts at meetings
At the start of each meeting the Chair asks for declarations of interest, and trustees must declare any relevant conflict, even if it is already on the register.
If a conflict is declared:
- It is recorded in the minutes
- The trustee may be asked to leave for that item
- They must not vote on the decision
Managing conflicts
The trustees manage conflicts using the Charity Commission's principles:
- Identify the conflict.
- Stop the conflicted person taking part in the decision.
- Manage the outcome in the CIO's best interests.
- Record how the conflict was handled.
Possible actions include removing the trustee from the discussion and decision, appointing an independent adviser where the conflict is substantial, declining quotes or contracts from conflicted people, and re-tendering work to make sure it is fair. If a conflict is so significant that it cannot be managed, the trustee may need to step aside from the role.
Failure to declare a conflict
Failing to declare a conflict may result in:
- Removal of the trustee from the meeting
- A request to resign from the board
- A report to the Charity Commission in serious cases
- The end of volunteer involvement, where appropriate
The CIO takes conflicts seriously to keep the public's trust.
Record keeping
Records include the register of interests, minutes noting conflicts and how they were managed, and the annual declaration forms. They are stored securely in Microsoft 365 SharePoint. Trustees and volunteers can get the declaration form from the Secretary.
Review
This policy will be reviewed every year, or sooner if guidance changes, a serious conflict occurs, or the trustees or the Charity Commission ask for it.
Related documents
- Bullying, harassment and conduct policy (including whistleblowing)
- Complaints policy
- Safeguarding policy
- Financial controls and reserves policy
- Hiring agreement
- Trustee code of conduct (governance manual)