Conflict of Interest Policy

Walsall Community Active Projects CIC

Company number 17051741

Conflict of Interest Policy

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1. Statement of Intent

Walsall Community Active Projects CIC is committed to acting in the best interests of our community. Decisions made in our name must be honest, fair and free from improper influence. This policy explains how we identify, declare and manage conflicts of interest.

This policy works alongside the conflict of interest provisions in our Articles of Association.

2. What is a Conflict of Interest?

A conflict of interest is any situation in which a person's private interests could affect, or appear to affect, how they carry out their role for the organisation.

Conflicts may involve:

• Financial interests: where a person, or a connected party, could gain or lose money.
• Non-financial interests: such as personal loyalty, professional reputation or political views.
• Conflicts of loyalty: where a person is involved with another organisation that has dealings with us.
• Connected parties: family members, close friends, business partners or organisations a person is involved with.

A conflict may be:

• Actual: a real conflict that exists now
• Potential: a conflict that could arise in the future
• Perceived: a situation that could look like a conflict to a reasonable outside observer

3. Why This Matters

Conflicts of interest, if not managed well, can:

• Damage trust in our organisation
• Lead to poor decisions
• Breach legal duties of directors
• Put funding and partnerships at risk
• Result in misuse of public money

Having a conflict of interest is not a problem in itself. Failing to declare or manage it is.

4. Who This Policy Applies To

This policy applies to:

• All directors and trustees
• All staff (paid and unpaid)
• All volunteers
• Contractors and consultants working in positions of influence
• Anyone else acting on behalf of the organisation

5. Declaring an Interest

Everyone covered by this policy must:

• Declare any interest they have on appointment to their role
• Update their declaration whenever circumstances change
• Declare an interest at the start of any meeting where a related matter is to be discussed
• Complete an annual review of declared interests

Declarations are made in writing using our Declaration of Interests form, and are recorded in our Register of Interests.

6. Examples of Interests to Declare

• Other paid or unpaid roles, including directorships and trusteeships
• Business interests, including ownership or partnership in companies
• Family or close personal relationships with other staff, trustees, suppliers or participants
• Significant financial interests in suppliers or partners
• Membership of political parties or campaigning organisations
• Gifts or hospitality received above a nominal value (we use £25 as a guide)
• Any role with a competing or partner organisation

7. Managing Conflicts in Decision-Making

Where a conflict exists, the person concerned will normally:

• Declare the conflict at the start of the meeting
• Leave the room during discussion of the matter, unless asked to stay to provide information
• Not vote on the matter
• Not be counted in the quorum for that item

The minutes will record the declaration, the discussion and the decision.

In some cases, the rest of the Board may decide that a director with a conflict can take part, in line with our Articles of Association. This decision and the reasons for it will be recorded.

8. Register of Interests

We keep a Register of Interests that records, for each person covered by this policy:

• Name and role
• Date of declaration
• Description of each declared interest
• How the interest is being managed
• Date of any change or update

The Register is reviewed at least once a year by the Board and is available for inspection by funders, regulators and (in appropriate form) members of the public on request.

9. Gifts and Hospitality

Staff, volunteers and trustees will:

• Not accept gifts or hospitality that could be seen as influencing their decisions
• Politely decline gifts above £25 in value, or pass them on to the organisation
• Declare any gift or hospitality offered or received above this value
• Never accept cash gifts

10. Procurement and Contracts

Where we are buying goods, services or appointing contractors, we will:

• Use fair and transparent processes
• Require all decision-makers to declare relevant interests
• Exclude conflicted individuals from supplier selection where appropriate
• Keep written records of decisions and reasons

Where a director, staff member or volunteer has an interest in a potential supplier (for example, a family member runs the business), this must be declared and approved by the Board before any contract is agreed.

11. Recruitment

Where a candidate for a role is related to or closely connected with an existing staff member, volunteer, trustee or contractor, the connection must be declared at the application stage. Conflicted individuals will not be involved in shortlisting, interviewing or decisions about that candidate.

12. Breach

Failure to declare or manage a conflict of interest properly may be treated as a disciplinary matter for staff, or grounds for removal from a volunteer or trustee role. Serious breaches may also be reported to the CIC Regulator, funders or other authorities where appropriate.

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Policy Review

This policy was adopted on 14 February 2026 and will be reviewed annually, with the next scheduled review in February 2027. It will also be reviewed earlier if there are significant changes in legislation, guidance, or our activities.

All staff, volunteers and trustees will be made aware of any updates and asked to confirm they have read and understood the revised version.

Signed on behalf of the Board