Policy on Managing Conflicts of Interest
No IPA officer or member of the Board of Representatives may receive any reward in connection with their service for the IPA, either directly or indirectly, and nor may their families or close friends. “Reward” means any benefit other than the reimbursement of actual and reasonable expenses incurred in the performance of their duties. Even where there is no financial benefit, trustees and committee members must avoid situations where they have a conflict of loyalties – such as being associated with an organisation with whom the IPA is doing business (and whose interests may not be the same as the IPA’s) including related organisations such as EPF, FEPAL, NAPsaC and APsaA. The IPA must also guard against damage to its reputation as a result of not properly managing conflicts of interest.
1) the IPA will keep a Register of Interests;
2) on appointment, every member of the Board of Representatives, all the officers, and every senior member of IPA staff who routinely attends a meeting of the Board of Representatives or ExCom, will complete a Declaration of Interests which will cover the interests of themselves, their immediate family and their close friends in regard to:
i. their employment;
ii. directorships of other boards or other executive/non-executive roles (including being an officer of an IPA society or a body in a related field);
iii. memberships of charities or not-for-profit bodies;
3) the Declarations of Interest will be compiled into a Register of Interests which will be held at Broomhills. The Register will be available for inspection by any member of the Board of Representatives or ExCom, or any staff engaged in procurement.
4) persons completing a Declaration of Interest will inform the Executive Director by email or in writing of any material change in their Interests as soon as that change occurs;
5) at least once each year, ExCom will formally review the Register of Interests, making recommendations to the Board if they wish to do so;
6) at the start of every meeting of the Board of Representatives or a committee which has control of funds, the agenda will include an item inviting Declarations of Interest. All Declarations will be formally recorded in the minutes. Committee members or staff arriving after the start of a meeting will make any Declarations of Interest as soon as they arrive;
7) members with a conflict (and, except in exceptional circumstances, staff in attendance with a conflict) will leave the room immediately before the item relating to their interest is reached and will neither discuss it, advise on it or vote on it, and nor will they count towards the quorum of the meeting while they are so absent. Where it is considered necessary for a member of staff with a conflict to remain in the room, the reason for that will be recorded in the minutes.
It is helpful if people wishing to stand for elections are screened – to ensure the IPA does not incur needless expense and the person concerned subsequent embarrassment – to ensure that a conflict of interest or other material factor would not disqualify them from holding an elected office. It is therefore proposed that the Committee on Elections should consider issuing a standard questionnaire to all prospective candidates for election, covering at least these issues:
1) Have you ever held office in your own Society? Please supply a list of offices and dates.
2) Has an Ethics Committee (whether of your own society, the IPA, or another relevant body) ever upheld a complaint against you? [It is proposed that answering “yes” to this question would disqualify the candidate.]
3) Are you involved in any commercial matters which would or would be likely to amount to a conflict of interest or loyalty, or to a perceived conflict of interest or loyalty*, if you were elected to office in the IPA? [Answering “yes” to this question would not necessarily disqualify a candidate.]
* For more information about the definitions of these please refer to the guidance on the website of the Charity Commission which can be found here.
Approved by the Board January 2012
*This change record is for background information only and does not form part of the Procedural Code. If there is any conflict between a statement in the Procedural Code and a statement in this change record, the change record will be disregarded.