1. Purpose and scope
The purpose of this Conflicts of Interest & Decision-Making Policy is to ensure that the HEADTURNED Foundation (the Foundation) makes decisions that are, and are seen to be, in the best interests of the Foundation and its mission.
The policy applies to trustees, directors, senior staff, and anyone else involved in formal decision-making on behalf of the Foundation. Others acting on behalf of the Foundation (such as consultants and key volunteers) are expected to follow its spirit.
2. What is a conflict of interest?
A conflict of interest is any situation in which a person's personal interests, or loyalties to another organisation or individual, could influence (or be perceived to influence) their decisions on behalf of the Foundation.
Conflicts of interest are not inherently wrong, but they must be identified, declared, recorded, and managed carefully.
Examples include (but are not limited to) situations where a decision-maker:
- Has a personal, financial, or organisational interest in a contract, grant, or partnership being considered.
- Has close family or personal connections with someone who may benefit from a decision.
- Holds a role with another organisation whose interests may overlap with, or diverge from, those of the Foundation.
3. Principles
Our approach to conflicts of interest is guided by principles such as:
- Transparency – potential conflicts are declared openly and recorded.
- Independence – decisions are taken based on what is best for the Foundation and its mission.
- Accountability – we keep appropriate records of conflicts and how they are managed.
4. Identifying conflicts of interest
Everyone involved in governance or decision-making is expected to consider whether they have any actual or potential conflicts in relation to the Foundation's work. This includes:
- Business or financial interests.
- Other roles (paid or voluntary) with external organisations.
- Personal, family, or close relationships that may benefit from decisions.
If in doubt, it is usually better to declare a potential conflict so it can be considered openly.
5. Declaring conflicts of interest
Conflicts of interest should be declared:
- On appointment or engagement (for example, via a declaration of interests form).
- At the start of relevant meetings, when agenda items where a conflict may arise are identified.
- As soon as possible if a new potential conflict arises between meetings.
Meeting chairs should routinely ask for any declarations of interest at the start of meetings and when appropriate during discussions.
6. Recording conflicts and maintaining a register
The Foundation will maintain a register of interests for trustees and, where appropriate, key decision-makers. This may include information about:
- Relevant roles with external organisations.
- Business or financial interests likely to interact with our work.
- Other relationships or interests that could give rise to conflicts in practice.
Individual conflicts declared at meetings should be recorded in the minutes, together with how they were managed (for example, a person withdrawing from part of the discussion).
7. Managing conflicts during decision-making
Where a conflict of interest is identified, the meeting chair (or another appropriate person) will decide how best to manage it. Possible approaches include:
- Allowing the person to provide factual information but not to influence the decision.
- Asking the person to withdraw from part of the discussion and decision.
- In some cases, deciding not to proceed with an arrangement in order to avoid an unmanageable conflict.
Decisions should be taken by individuals who do not have a conflict in relation to the matter, and meetings should remain quorate after conflicted individuals withdraw.
8. Gifts, hospitality and other benefits
Gifts, hospitality, or other benefits offered to individuals in connection with Foundation business can create real or perceived conflicts of interest.
The Foundation may maintain simple guidelines or registers for gifts and hospitality. As a general principle, individuals should not accept anything that could reasonably be seen as intended to influence decisions.
9. Relationship to other policies
Conflicts of interest may also interact with other policies, such as:
- Our Ethical Fundraising & Sponsorship Policy, which guides decisions about accepting or declining support.
- Our Whistleblowing & Serious Concerns Policy, which provides routes to raise concerns about governance or decision-making if something feels wrong.
10. Review and updates
This policy will be reviewed periodically and updated where necessary to reflect changes in the Foundation's structure, activities, or governance requirements.
The version published on the HEADTURNED Foundation website is the version currently in force.