Policy 2 of 6
Conflict of Interest Policy
To make sure decisions are made in the interests of the organisation and the people it serves, and are seen to be.
ADOPTED
This policy was adopted by the board of The Schaffa Foundation, recorded as adopted on 22 September 2026. It is reviewed at least every two years, and sooner if the law changes or an incident shows a gap.
What counts as a conflict
A conflict of interest exists whenever a person’s duty to the organisation could be affected by a personal, family, financial or other outside interest. It does not matter whether the person believes they can act impartially — what matters is whether a reasonable outsider might doubt it.
- Awarding work, or buying goods or services, from a business connected to a board member, staff member or volunteer, or to their family.
- Employing, engaging or supervising a family member or close friend.
- Holding a position with another organisation that competes for the same funding.
- Accepting a gift, discount or hospitality from a supplier or funder beyond a token courtesy.
- Any personal benefit arising from a decision the person takes part in.
IN PRACTICE
A small charity runs on the goodwill of people who know each other, and an in-kind or discounted arrangement with a connected business is often genuinely the best outcome available. The point of this policy is not to prevent that. It is to make sure it is declared, decided by others, and written down.
Declaring a conflict
- Board members complete a declaration of interests on appointment and update it whenever something changes.
- Conflicts of interest are a standing item at the start of every board meeting.
- Anyone who becomes aware of a conflict during a discussion declares it immediately, even if it should have been declared earlier.
- The declaration, and what was decided about it, is recorded in the minutes.
Managing a conflict
Once declared, the remaining board members decide how to manage it. Depending on how significant it is, the person may take part in the discussion but not the vote, or leave the room for both. For a material conflict, leaving the room is the default.
A conflicted person must not use their position to influence the decision informally, before or after the meeting.
Where the organisation enters into a transaction with a related party, the terms must be no less favourable to the organisation than an arm’s length arrangement, and the decision must be documented.
Register of interests
A register of declared interests is maintained by the secretary and reviewed annually by the board.
The register itself is not published here. It records real people’s personal and financial interests, and is held in the Foundation’s governance system rather than in a public document. Board members can view it at any time, and it is made available to auditors and funders on request.