Conflict of interest policy

Aims and scope

This document is to ensure that all work that is carried out for, or on behalf of Waverley Training Services (WTS), is free from improper influence and is independent, fair, and devoid of bias.

All persons to whom this policy applies must avoid making decisions or handling matters where they have an interest that might influence, or be perceived to influence, their judgment.

They must avoid putting themselves in a position where there is or may be a conflict between the duties required as set out in their contract with WTS and their own private interests.

Purpose

The purpose of this document is to provide support, clarification, and guidance on managing conflict of interest. WTS requires all employees and third parties providing services; to carry out their duties and activities associated with their work with the utmost integrity and professionalism. This includes the avoidance of situations giving rise to actual or potential conflicts of interest.

This policy sets out the expectations regarding real and potential conflicts of interest and the procedures to be followed in the event of a conflict of interest arising.

This policy applies to:

1. All WTS employees, Learners, contractors, agency, and/ or temporary workers.
2. All consultants and other service providers, including examiners, engaged by WTS in the development, delivery or award of its qualifications and examinations.

The policy does not apply to Governors. Separate procedures are in place to manage conflicts of interest at board level in accordance with Waverley Borough Council (WBC) procedures.

This policy is underpinned by quality assurance guidance issued by Awarding Organisations and partners.

This includes:

• Joint Council for Qualifications (JCQ) Instructions for conducting examinations.
• City and Guilds Centre Handbook.
• Association for Accounting Technicians AAT:
• Guidance for Training Providers.
• Code of Practice.

What is a Conflict of Interest?

In the General Conditions of Recognition (Condition A4), Ofqual states that a conflict of interest exists where:

1. The interests of an awarding organisation in any activity undertaken by it, on its behalf, or by a member of its group have the potential to lead it to act contrary to its interests in the development, delivery, and award of its qualifications.
2. A person who is connected to the development, delivery, or award of qualifications by the awarding organisation has interests in any other activity which have the potential to lead that person to act contrary to his or her interests in that development, delivery, or award.
3. An awarding organisation must take all reasonable steps to avoid any part of the assessment of a Learner (including by way of Centre Assessment Standards Scrutiny) being undertaken by any person who has a personal interest in the result of the assessment.
4. Where, having taken all such reasonable steps, an assessment by such a person cannot be avoided, the awarding organisation must make arrangements for the relevant part of the assessment to be subject to scrutiny by an-other person.
5. An informed and reasonable observer would conclude that either of these situations is the case.

Put simply, a conflict of interest is a private interest which might influence a person’s judgment in carrying out contractual duties for an awarding organisation and thereby undermine the actual or perceived independence and integrity of that awarding organisation.

Examples of Conflicts of Interest

A personal relationship, whether declared. For example, an examiner could have a personal relationship with a person who is due to take an assessment. This might include a close professional relationship, friendship, a family tie (e.g., son/daughter, cousin, niece, or other family member), another example may include a romantic relationship.

• A contractual relationship, for example, where an examiner is also a candidate’s tutor or employed in the centre where he/she is conducting examinations.
• A person who has had access to confidential assessment information and has been or is involved in the preparation of a resource designed to support the preparation of candidates for assessment.
• Assessments set by employees and third parties who have been involved in the preparation of a resource designed to support the preparation of candidates for assessment.
• A relationship where one individual is beholden to the other. For example, this might occur where gifts or hospitality have been exchanged, or money has been borrowed or bribes accepted.
• This does not apply to the preparation of teaching resources or materials by a tutor exclusively for candidates that he or she teaches. However, these materials may be monitored by WTS to deter and detect any breach of confidentiality.

Procedures to be followed to identify possible conflicts

Where you encounter an unexpected actual or perceived conflict of interest, you need to raise it immediately with your line manager and, in any event, before you conduct the activity affected by the conflict of interest.

For example, if you are an examiner and find yourself presented with a candidate that you are related to or is otherwise linked to you through a personal or professional connection, you should raise this conflict immediately with one of our Senior Management team.

Where you discover the existence of an actual or conflict of interest after the activity to which the conflict might apply has taken place, you will need to inform your line manager immediately.

You will be asked to make a record of the activity and the fact that you were unaware at the time of any conflict of interest and provide details of when and how you became aware of the conflict.

In both instances your Conflicts of Interest Disclosure Form must also be updated.

Consequences of breach of this policy

Compliance with this policy is mandatory and any breaches may result in:

1. Disciplinary proceedings up to and including dismissal for employees.
2. Immediate termination of contract for a consultant, contactor, or other service provider.

Monitoring and review

This policy will be monitored reviewed annually.

Employee Declaration Form can be sent upon request.