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Conflict of Interest Policy

Last Updated:

Table of Contents

1. General

1.1 This policy applies to all BII Training centre staff, including all staff who assess, internally verify and administer qualifications.

1.2 This policy sets out guidance on how to identify and manage a Conflict of Interest and the procedures to follow.

1.3 The Conflict of Interest Policy supports the Centres commitment to integrity by encouraging the declaration of conflicts of relevant interests so that they be appropriately managed

 

2. The aim:

2.1 BII Training is committed to maintaining rigorous quality standards and ensuring that it complies with regulatory requirements and best practice. The Centre manages this commitment through continual risk assessments and takes all reasonable steps to prevent Conflicts of Interest from occurring; and to manage Conflicts of Interest to prevent any adverse effect

2.2 The Centre is responsible for this policy and for ensuring that there are appropriate systems in place to promote and monitor compliance with it.

 

3. Responsibility and Implementation:

3.1 The Head of Finance and Services has overall responsibility for the effective operation of this policy and for ensuring compliance with the relevant statutory framework. This committee delegates day-to-day responsibility for operating the policy and ensuring its maintenance and review to the Head of Training.

3.2 Team leaders and Managers have a specific responsibility to ensure the fair application of this policy and all employees are responsible for supporting colleagues and ensuring its success.

3.3 It is the responsibility of all employees to adhere to this policy and, wherever possible, to resolve issues informally. The implementation of this policy on an operational level is the responsibility of the Head of Training.

3.4 The principles on which these requirements are based are that employees must ensure their personal interests do not conflict with their duty or the interests of the Centre.

3.5 The BII Training Centre acknowledges that there is a wide range of situations in which conflicts of interest may arise and will strongly encourage staff to seek advice where necessary.in the verification and evaluation of assessment.

 

4. What is a Conflict of Interest:

4.1 A conflict of interest arises where there is an actual or potential risk or a perceived conflict of commitments which might affect an individual acting in the best of interests of the Centre.

4.2 This may arise where a learner or individual might be seen to be influencing matters for actual or potential personal benefit or when a member of staff is in a position to influence, directly or indirectly, in ways that could lead to gain for them, their family or others.

4.3 Examples of situations in which conflicts of interest, both for financial or personal gain, include: –

  • Where there is or there is the potential for there to be personal gain or gain to immediate family/close contact/associate.
  • Where an individual is in a position to directly or indirectly enhance their career or the career of others with whom they are personally associated.

4.4 Any individual concerned should also consider the perspective of an independent external observer and whether they would perceive there to be a conflict of interest.

 

5. Declare Interest

5.1 All BII Training staff are required to sign a Conflict-of-Interest statement annually to declare identified potential or actual conflict between a learner and a member of staff. If there is any doubt that the interest is a conflict, it is recommended that it should be declared and the Head of Finance and Services will make the decision, so that BII Training can mitigate against any adverse effect.

The information provided by key stakeholders will be processed in accordance with data protection principles as set out in the Data Protection Act 1998. Data will be processed only for the purpose set out in this policy and not for any other purpose

5.2 While an interest may not necessarily give rise to a conflict, in the interests of transparency, it should still be declared.

5.3 If a conflict of interest is not declared at the outset, this may constitute a breach of BII Ethics and, depending on the nature of the conflict, could lead to disciplinary action.

 

6. Resolution of Conflict

6.1 The Head of Finance and Training will be advised of any conflict of interest declared and will then:

  • Assess the nature of the conflict.
  • Assess the risk or threat to the function of BII Training.
  • Decide whether the conflict is non trivial.
  • Decide what steps to take to avoid or manage the conflict or adverse effect.

6.2 The purpose of the discussion is to reach a decision about how the conflict will be managed. Generally, the discussion will take place between the Head of BII Training and the Head of Finance and Services, unless they are involved. In this case, an appropriate replacement will be used. The individual raising the possibility of a conflict will also take part in the discussion, if this is appropriate.

 

7. Decision

7.1 Normally it will be sufficient to:-

  • Gain an undertaking from the learner or individual to conduct their responsibilities in such a way that the integrity of BII Training is maintained, as well as their own integrity.
  • Reorganise activities and/or key functions so that the conflict is mitigated.

7.2 If neither of the above steps is possible, another solution must be agreed by the Head of Finance and Services. The solution should be in proportion to the nature of the conflict; in extreme circumstances, activities may need to be monitored or even restricted. The decision as to how the conflict is managed is final.

 

8. Interests in assessment

8.1 BII Training will take all reasonable steps to avoid any part of the assessment of a Learner (including Moderation) being undertaken by any person who has a personal interest in the result of the assessment. Where, having taken all such reasonable steps, an assessment by such a person cannot be avoided, BII Training will make arrangements for the relevant part of the assessment to be subject to scrutiny by another person/body

8.2 BII Training requires all staff and contractors to declare any involvement in the preparation of any resource or learning materials designed to support learners, or likely learners, in the assessment of any qualification for which they are under contract. Any such declarations will be carefully monitored to ensure that those assessments are not compromised.

 

9. Log conflict and resolution

9.1 A Declaration of Interest Form is provided for this purpose; it must be completed by all relevant stakeholders and returned to BII Training so that it can be recorded on the full register.

9.2 Any unresolved matter shall be referred to the Head of Finance and Services.

9.3 Should the conflict of interest concern the Head of BII Training, then this will be declared to and resolved by the Chief Executive.

 

10. Monitor and Review of the Register

10.1 BII Training is responsible for maintaining the register of interests and will:-

  • Record in the register all conflicts and interests.
  • Circulate amendments or additions to the register (if any) to the BII Board.
  • Keep a log of any actions taken to manage a conflict of interest.

10.2 The register of conflicts and interests will be available for inspection by interested stakeholders. At least once in every 12-month period, all BII Training staff are required to complete a new Declaration of Interest Form and a new Conflict of Interest register is created.

11. Policy review:

11.1 This policy is reviewed annually to ensure it continues to meet our needs and those of our learners, customers and regulators.