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INTRODUCTION

UniAthena has adopted this Policy to address conflicts of interest, so as to ensure that all activities are conducted against the highest standards of ethics and integrity. As an organisation we have a duty to fulfil the highest standards of ethical practice. Where an individual has a private interest (financial or otherwise) which could overlap with their duties for UniAthena then this interest must be disclosed and managed appropriately. 

This Policy sets out the mechanism for doing so.

DEFINITIONS

A conflict of interest is a situation where an individual’s private interests are in (or may appear to be in) conflict with the interests of UniAthena. It is not that individuals cannot have private interests, but rather that these interests should be declared where they might reasonably be foreseen to be in conflict.

This policy covers all conflicts – whether real or perceived. Put differently, where there might appear to be a conflict of interests when viewed from outside the organisation, then these must be declared.

This Policy, therefore, is a mechanism for protecting UniAthena (and its staff and Directors) against criticism or compromise by ensuring that they recognise and disclose such conflict situations and take steps to avoid or manage them.

SCOPE

This policy applies to all employees, contractors, consultants and volunteers of UniAthena.

DETERMINING WHETHER A CONFLICT EXISTS

The majority of interests will not create a conflict, but it is each individual’s responsibility to consider whether there is an actual or perceived conflict between interests (regardless of whether they are subject to the explicit declaration process) in so far as they relate to their activities with UniAthena. Even where an individual has declared an interest they are still responsible for considering and identifying potential conflicts.

If an individual believes they have an actual or potential conflict of interest, or if they are unsure if a conflict exists, they should discuss it with the HR Head in the first instance. The HR Head  will work with the CEO or Chair of the Board of Directors (in the case of Directors) to determine what action might be needed. This may include requiring the individual concerned to recuse themselves from consideration of particular issues.

At the start of all meetings of the Board of Directors or its committees, an opportunity will be presented to note any conflicts that are likely to arise based on the business of the meeting. Whilst the same arrangement does not apply to other meetings, it is important that conflicts are declared to all present.If a conflict arises, it is not sufficient to rely on a declaration made previously – the conflict itself must be identified.

MANAGING CONFLICTS

Upon disclosure, management will review the situation and decide on the appropriate action, which may include:

  • Recusing the individual from specific decisions or discussions.
  • Reassigning their duties to avoid the conflict.
  • Implementing additional oversight or checks in decision-making processes.
  • Maintaining a register of all disclosed conflicts for transparency and accountability.
  • Management strategies will be reviewed annually or when significant changes occur to ensure they remain effective.

REGISTER OF INTERESTS

All disclosed interests will be noted on a Register of Interests, maintained by the HR head. Access to the disclosures will be restricted in line with the principles of data protection in place within the Group.

In order to ensure that the information on the register is relevant and current, staff will be required to review their declarations on an annual basis.

CONCLUSION

Most situations will require no more than a declaration of the interest or activity which will be stored on the Register of Interests. There will, however, be some instances which need to be dealt with by agreeing how the conflict can be managed. In these instances, the agreed approach should be documented between the HR Head and the individual. It is the responsibility of those affected to comply with the approach that has been agreed.