Declaration of Interest Policy

Adopted on: 1 April 2025

Review Date: April 2030

Purpose

This policy ensures that actual, potential, or perceived conflicts of interest are identified and managed properly to protect the integrity and reputation of the Confederation and ensure compliance with the Charity Commission’s guidance (CC29).

Scope

This policy applies to:

• Trustees
• Contractors and consultants
• Members of the Advisory Council
• Volunteers in decision-making roles

Definition of a Conflict of Interest

A conflict of interest arises when a person’s duty to act in the best interests of the charity could be compromised by a competing interest. This includes:

• Financial interests (e.g. contracts, ownership in a supplier)
• Non-financial interests (e.g. affiliations, personal relationships, professional roles)
• Perceived conflicts (where an impartial observer might reasonably question objectivity)

Declarations of Interest

Annual Declarations:

All covered individuals must complete a Declaration of Interests form annually, detailing:

• Any directorships or significant shareholdings
• Contracts with or payments from the charity
• Close relationships with other stakeholders
• Membership in other organisations where interests may overlap

Ongoing Duty to Declare:

If a new interest arises during the year, it must be declared immediately to the Board or Charity Secretary.

Register of Interests

The charity will maintain a Register of Interests held securely by the ED. This will be reviewed annually and made available to the Board.

Managing Conflicts of Interest

When a declared interest is relevant to a decision:

• The individual must declare it at the start of the meeting
• The interest will be recorded in the minutes
• The person may be asked to withdraw from the discussion and/or not vote
• In exceptional cases, a conflict may prevent someone from continuing in their role

The Chair (or delegated trustee) is responsible for managing the process and ensuring consistency.

Contractors and Advisors

Contractors and Advisory Council members must:

• Sign a declaration form on appointment
• Not be involved in decisions related to their own contracts or services
• Declare any potential conflict when tendering for work or partnerships

Transparency and Publication

The charity may publish a summary of trustees’ declared interests on its website in line with best practice.

Breaches of Policy

Failure to declare interests or comply with this policy may result in:

• Exclusion from meetings or discussions
• Termination of contract (for contractors)
• Referral to the Charity Commission if misconduct is suspected

Review and Approval

This policy will be reviewed every five years or sooner if governance guidance changes.