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Conflict of Interest Policy

A conflict of interest policy requires employees to disclose situations where personal interests could influence, or appear to influence, their work decisions — relatives in the company or at vendors, side businesses, moonlighting, shareholdings in suppliers or competitors and outside directorships. It sets how conflicts are declared, assessed and managed.

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[Company Logo][Company Name]

CONFLICT OF INTEREST POLICY

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

  1. Employees must avoid conflicts where possible and disclose all actual, potential or perceived conflicts promptly.
  2. 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.
  3. Employees must not have a financial interest of more than [Number]% in a supplier, customer or competitor without disclosure and approval.
  4. Outside employment, freelancing or business requires prior written approval; work for a competitor or that uses company time, assets or information is not permitted.
  5. Outside directorships require prior approval of [Authorised Signatory].
  6. Employees must not use their position to obtain personal benefits or business opportunities that belong to the company.

5. Procedure

  1. Employees complete the declaration form at joining, annually by [Month] and whenever circumstances change.
  2. HR/Compliance reviews each declaration with the manager within [Number] working days.
  3. Mitigation may include recusal from decisions, change of reporting line, reassignment or divestment.
  4. 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]

What this template includes

  • Examples of conflicts — relatives, investments, outside work, gifts
  • Moonlighting rule — prior approval, no competing work
  • Relatives and relationships — no reporting or approval over each other
  • Declaration at joining, annually and when circumstances change
  • Assessment and mitigation — recusal, reassignment, divestment
  • Declaration form

When to use it

  • An employee's relative owns a vendor firm
  • Employees take up freelance or second jobs
  • Couples or family members work in the same reporting line
  • Introducing an annual conflict-of-interest declaration

How to customise this template

  1. 1Define 'relative' for your company
  2. 2Decide whether any outside work is allowed and on what terms
  3. 3Name who reviews declarations
  4. 4Set the shareholding threshold that must be declared
  5. 5Attach the form to your onboarding pack

HR tips

  • A declared conflict is usually manageable; a hidden one becomes misconduct
  • Have people step out of decisions where they have an interest
  • Review declarations from procurement and finance teams closely
  • Keep declarations confidential

Restrictions on outside work must be reasonable and connected to the employer's legitimate interests. Review this template with your appointment letters, standing orders and legal advice.

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Frequently asked questions

What is moonlighting?+

Moonlighting is taking up a second job or business alongside regular employment. Many companies require prior approval and prohibit work for competitors or work that uses company time or information.

Can relatives work in the same company?+

Usually yes, if the relationship is declared and neither person supervises, appraises or approves anything for the other.

What happens if a conflict is not declared?+

Failure to disclose a known conflict is usually treated as misconduct, even if no actual harm happened, because it denies the company the chance to manage the risk.

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