Conflict of Interest Policy

Introduction

1. • This policy applies to all members of the Board of Governors and its committees at LCPS. It sets out guidelines and procedures for identifying, monitoring, and managing actual and potential conflicts of interest. Any potential conflicts of interest which may arise in relation to members of staff and external consultants at LCPS will be addressed by the relevant contracts of employment or engagement.

1. • In this policy references to:

Conflicts or “conflicts of interest” include actual and/or potential conflicts of interest and/or duty.

persons who are “connected” with a governor, member of staff or external consultant of LCPS means: a child, stepchild, grandchild, parent, brother or sister of a governor, member of staff or external consultant of LCPS.

the spouse, unmarried partner or civil partner of a governor, member of staff or external consultant of LCPS.

any person who is in a business partnership with a governor, member of staff or external consultant of LCPS or any person who is in a business partnership with any person falling within paragraph (i) or (ii) above.

any company, business, trust, or organisation in which a governor, member of staff or external consultant of LCPS (or any other person connected to them) has an interest as a beneficiary or through ownership, control or influence.

If in doubt about whether a person is connected, a governor, member of staff or external consultant of LCPS should seek advice from LCPS’s Senior Human Resources Manager.

benefit includes any payment or material benefit (including property, loans, goods, and services), other than reasonable out of pocket expenses.

1. The Purpose of this Policy

2.1 The governors, members of staff and external consultants of LCPS have a duty to act in the best interests of LCPS. This means that the governors, members of staff and external consultants of LCPS must not place themselves in a position where they have, or may have, a direct or indirect interest that conflicts with their duties as governors, members of staff and external consultants of LCPS.

2.2 Conflicts of interest can inhibit open discussions and may result in governors, members of staff and external consultants of LCPS taking irrelevant considerations into account or making decisions that are not in LCPS’s best interests. All governors, members of staff and external consultants of LCPS must therefore be alert to the possibility that they, or their colleagues, could be affected by a conflict of interest.

2.3 The procedures in this policy will enable governors, members of staff and external consultants of LCPS to identify and manage conflicts of interest so that they can ensure that conflicts do not prevent them from making decisions in the best interest of LCPS. The policy will also help protect both LCPS and governors, members of staff and external consultants of LCPS from any appearance of impropriety in cases where conflicts of interest arise.

1. Identifying Conflicts of Interest

1. • A conflict of interest is any situation in which a governor’s, member of staff or external consultant’s direct or indirect interests could, or could be seen to, prevent them from deciding only in the best interests of LCPS.

1. • When considering if they have a conflict of interest, governors, members of staff and external consultants of LCPS must be aware of the following principles.

1. • A conflict of interest exists if there is a possibility that their personal interests could influence their decision-making, even if their decision-making is not in fact adversely affected by the conflict; and the interest that gives rise to a conflict may be direct or indirect.

1. Procedure for Declaring Interests

1. • All governors, members of staff and external consultants of LCPS have a personal responsibility to declare any interest that might reasonably be regarded as potentially giving rise to a conflict.

1. • On appointment, all governors must complete a declaration of interests’ form (Annex 1):

1. listing any personal interests, business interests or other direct or indirect interests that might potentially give rise to a conflict of interests.

1. listing any interests of persons connected to them that may potentially give rise to a conflict of interest.

1. Confirming that they are not aware of any conflict, other than those already disclosed, that exists between their role and their personal circumstances or other interests.

1. confirming that they will update the form annually, or sooner if any changes occur.

1. confirming that they will declare any conflict that arises in the future.

1. • The information provided by governors, members of staff and external consultants must be recorded in a register of interests. At least once in every 12-month period, all governors must review the information relating to them contained in the register of interests and declare that the information is correct or make a further declaration if necessary.

1. • It is for everyone to decide which matters to declare but, if in doubt, they should make a declaration. If they would like to discuss the issue, they may contact LCPS’s Deputy CEO or Senior HR Officer for confidential guidance.

1. • The information provided will be processed in accordance with the principles for processing personal data set out in UK data protection legislation. Data will be processed only for the purposes set out in this policy and not for any other purpose.

1. Procedures for Managing Conflicts

5.1 If a conflict arises and depending on the seriousness of the conflict, the conflicted individual must withdraw from relevant discussions or decision-making processes, not pursue the course of action that gives rise to the conflict or resign.

1. Enforcing and reviewing this, Policy.

6.1 Any failure to comply with the terms of this policy could result in disciplinary action taken against the conflicted person.

6.2. This policy must be reviewed annually, or sooner if required.

DECLARATION OF INTEREST FORM

I confirm that to the best of my knowledge I have declared all of my interests in line with LCPS’s Conflict of Interest Policy.

Name (Print): ___________________________________

Signed: ____________________________________

Date: _____________________________________

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