Conflict of Interest Policy

Procedure Brief and Purpose

The purpose of this policy is to assist the charity trustees of the NWSPCA to effectively identify, record and manage any conflicts
of interest in order to protect the integrity of the NWSPCA and to ensure that the charity trustees act in the best interest of their
charity.

Objective

The NWSPCA management committee aims to ensure that the charity trustees are aware of their obligations to disclose any
conflicts of interest that they may have, and to comply with this policy to ensure they effectively manage those conflicts of
interest as representatives of the NWSPCA.

Scope

This policy applies to the trustees of the NWSPCA.

Definition of conflicts of interests

A conflict of interest is any situation in which a charity trustee’s personal interests or loyalties could, or could be seen to,
prevent the charity trustee from making a decision in the best interests of the charity. This personal interest may be direct or
indirect and can include interests of a person connected to the charity trustee. These situations present the risk that a person
will make a decision based on, or affected by, these influences, rather than in the best interests of the charity and therefore
must be managed accordingly.

Policy

This policy has been developed because conflicts of interest commonly arise, and do not need to present a problem to the
charity if they are openly and effectively managed. It is the policy of the NWSPCA as well as a responsibility of its charity
trustees, that ethical, legal, financial or other conflicts of interest be avoided and that any such conflicts (where they do arise) do
not conflict with their obligations to the NWSPCA.
The NWSPCA will manage conflicts of interest by requiring charity trustees to:

• avoid conflicts of interest where possible.
• identify and record any conflicts of interest.
• carefully manage any conflicts of interest, and
• follow this policy and respond to any breaches.

Responsibility of the board of charity trustees

The board is responsible for:

• establishing a system for identifying, disclosing and managing conflicts of interest across the charity.
• monitoring compliance with this policy and
• reviewing this policy on an annual basis to ensure that the policy is operating effectively.

The charity trustees should ensure they are aware of their legal obligations in the management and control of their charity and
should refer to the Charities Regulator’s ‘Guidance for Charity Trustees’ for further information on this see the Charities Regulator website.

Identification and disclosure of conflicts of interest

Once an actual, potential, or perceived conflict of interest is identified, it must be entered into the NWSPCA’s register of
interests, as well as being raised with the board of charity trustees.
The register of interests must be maintained by the Secretary, and record all information related to a conflict of interest
(including the nature and extent of the conflict of interest and any steps taken to address it).

Confidentiality of disclosures

To support charity trustees to disclose their conflicts of interests, access to the Register of Interests will be restricted to the
Executive Committee.

Action required for management of conflicts of interest

Once the conflict of interest has been appropriately disclosed, the board of charity trustees (excluding the disclosing charity
trustee and any other conflicted person) must decide whether a conflicted charity trustee should:

• vote on the matter (this is a minimum)
• participate in any debate, or
• be present in the room during the debate and the voting.

In exceptional circumstances, such as where a conflict is very significant or likely to prevent a charity trustee from regularly
participating in discussions, it may be worth the board of charity trustees considering whether it is appropriate for the person
with the relevant conflict to resign from the board of charity trustees.

What should be considered when deciding what action to take?

In deciding what approach to take, the board of charity trustees will consider whether:

• the conflict needs to be avoided.
• simply documenting the conflict will suffice.
• the conflict will realistically impair the disclosing person’s capacity to impartially participate in
  decision-making.
• alternative options to avoid the conflict should be used.
• there is the possibility of creating an appearance of improper conduct that might impair confidence
  in, or damage the reputation of, the charity.

The approval of any action requires the agreement of at least a majority of the board of charity trustees (excluding
any conflicted charity trustee) who are present and voting (if applicable) at the meeting.
All details regarding the conflict of interest, including the action arising, will be recorded in the minutes of the
meeting.

Compliance with this policy

If the board of charity trustees has a reason to believe that a person subject to this policy has failed to comply with it, it will
investigate the circumstances. If it is found that this person has failed to disclose a conflict of interest, the board of charity
trustees may take action against the person. This may include seeking the person’s resignation from the charity.
If a person suspects that a charity trustee has failed to disclose a conflict of interest, they must either:

• Discuss the conflict with the relevant person.
• Notify the Secretary the Society of the conflict and any action taken.
• Notify the Management Committee

This policy was reviewed by the Board at the October 2024 meeting on 07/10/2024 and was approved