[Company Logo][Company Name]
- Policy No.:
- [Reference Number]
- Version:
- [Version Number]
- Effective Date:
- [Date]
- Policy Owner:
- Human Resources & Compliance
1. Purpose
Employees of [Company Name] must make decisions in the best interest of the company. This policy helps identify, disclose and manage situations where personal interests could conflict with that duty.
2. Scope
It applies to all employees, directors and consultants, and covers interests of their relatives.
3. Definitions
- Conflict of interest: a situation where a personal, financial or family interest could influence, or appear to influence, an employee's judgement.
- Relative: spouse, parents, children, siblings, in-laws and [others].
- Outside activity: any paid or unpaid work, business, directorship or advisory role outside the company.
4. Policy
- Employees must avoid conflicts where possible and disclose all actual, potential or perceived conflicts promptly.
- Relatives may not be in a direct or indirect reporting line, and an employee must not take part in hiring, appraising or paying a relative.
- Employees must not have a financial interest of more than [Number]% in a supplier, customer or competitor without disclosure and approval.
- Outside employment, freelancing or business requires prior written approval; work for a competitor or that uses company time, assets or information is not permitted.
- Outside directorships require prior approval of [Authorised Signatory].
- Employees must not use their position to obtain personal benefits or business opportunities that belong to the company.
5. Procedure
- Employees complete the declaration form at joining, annually by [Month] and whenever circumstances change.
- HR/Compliance reviews each declaration with the manager within [Number] working days.
- Mitigation may include recusal from decisions, change of reporting line, reassignment or divestment.
- Decisions are recorded and kept confidential.
| Employee Name | |
|---|
| Employee ID | |
|---|
| Designation | |
|---|
| Nature of interest (relative / investment / outside activity / other) | |
|---|
| Details of person or entity involved | |
|---|
| Business relationship with the company | |
|---|
| Date the interest arose | |
|---|
Declaration: I confirm that the above is complete and true and that I have no other conflict of interest. I will update this declaration if my circumstances change.
6. Responsibilities
- Employees: disclose honestly and on time.
- Managers: identify conflicts in their teams.
- HR/Compliance: review, decide mitigation, maintain records.
7. Non-compliance
Failure to disclose a conflict or breach of an agreed mitigation will be dealt with under the Disciplinary Policy.
8. Review & Approval
This policy is reviewed annually.
Reviewed by
[HR Name]HR / Compliance
Date:
[Date]Declared by
[Employee Name]Date:
[Date]