Trustee Conflict of Interest

Introduction

This policy is informed by the Charity Commission’s guidance Conflicts of Interest: A Guide for Charity Trustees (CC29), available at:
https://www.gov.uk/government/publications/conflicts-of-interest-a-guide-for-charity-trustees-cc29

It should be read in conjunction with the charity’s governing document, which outlines the legal framework within which the trustees of Technology Books for Children must operate.

This policy applies to all trustees and aims to protect the integrity, objectivity and independence of the charity’s decision-making process.

What is a Conflict of Interest?

A conflict of interest is any situation where a trustee’s personal interests, or interests owed to another organisation, could (or could be seen to) influence their ability to make decisions in the best interests of Technology Books for Children.

Conflicts can be:

• Financial: where a trustee (or someone close to them) could benefit financially.
• Non-financial or loyalty-based: where a trustee’s duty to another organisation or relationship could compete with their duty to the charity.

Examples include:

• A trustee’s business being awarded a contract by the charity.
• A trustee’s relative applying for a paid or voluntary position.
• A trustee sitting on the board of another organisation applying for funding from the charity.

Identifying and Declaring Conflicts

All trustees must:

• Review and declare any existing or potential conflicts at the start of their term and update these as necessary.
• Declare any conflicts of interest prior to every board or committee meeting. A standing agenda item will be included to prompt declarations.
• Self-identify and raise any possible conflict of interest as soon as it arises.

Recording Conflicts

All declared or identified conflicts will be:

• Recorded in a Register of Interests, held by the charity.
• Logged in the minutes of the relevant meeting, along with the actions taken to address the conflict.

Managing Conflicts of Interest

If a conflict arises, the trustees will take one or more of the following steps, as appropriate:

• Withdraw the affected trustee from the discussion and decision-making process.
• Exclude the conflicted trustee from receiving relevant papers.
• Delegate the decision to a sub-committee or independent adviser.
• In extreme cases, the trustee may be asked to consider stepping down from their role if the conflict is ongoing and cannot be managed appropriately.

Trustees who are conflicted may not:

• Count towards the quorum for the discussion.
• Vote on the matter.
• Attempt to influence the decision either inside or outside the meeting.

Trustee Responsibilities

All trustees have a legal duty to:

• Act in the best interests of the charity.
• Ensure decisions are made independently and free from bias or undue influence.
• Avoid situations where personal interests could conflict with their duty.
• Follow the charity’s governing document and the Charity Commission’s guidance.

Breaches of this Policy

Failure to disclose or properly manage a conflict of interest may be considered a breach of trust and could:

• Lead to reputational or legal consequences.
• Result in regulatory investigation.
• Affect the validity of board decisions.

In such cases, the matter will be addressed by the Board and, where necessary, reported to the Charity Commission.

Review of This Policy

This policy will be reviewed annually or sooner if required by:

• Changes to relevant legislation or Charity Commission guidance.
• Structural or operational changes within the charity.

Further Information and Guidance

Trustees are encouraged to refer to:

• The Charity Commission’s full guidance:
  https://www.gov.uk/government/publications/conflicts-of-interest-a-guide-for-charity-trustees-cc29
• The charity’s governing document, which may specify additional rules on conflicts of interest.

Any queries or concerns about potential conflicts should be raised with the Chair of Trustees – Rebecca Franks – Rebecca@technologybooksforchildren.org

Version Control and Review

This policy will be reviewed annually and as needed to ensure effectiveness and compliance.