Conflict of Interest Policy – DRAFT

1. Purpose

Greystoke Community Land Trust (“the CLT”) is committed to acting openly, honestly and in the best interests of the community.

This policy explains how actual, potential and perceived conflicts of interest will be identified, declared and managed to protect both the CLT and its Directors.

2. Scope

This policy applies to:

  • Directors 
  • Officers 
  • Members of committees or working groups 
  • Volunteers acting on behalf of the CLT where appropriate 

3. What is a Conflict of Interest?

A conflict of interest exists where a person’s personal, financial or other interests could influence, or reasonably be perceived to influence, their ability to act solely in the interests of the CLT.

Conflicts may be:

  • Actual – a conflict currently exists. 
  • Potential – a conflict could arise in the future. 
  • Perceived – others could reasonably believe a conflict exists, even if none actually does. 

4. Examples

Examples include:

  • applying for CLT housing; 
  • a family member applying for CLT housing; 
  • owning land or property affected by a CLT project; 
  • employment with, or ownership of, a contractor tendering for CLT work; 
  • membership of another organisation with related interests; 
  • Parish Councillors participating in decisions affecting both organisations. 

Having an interest does not prevent someone serving as a Director. It simply means the interest must be declared and managed appropriately.

5. Declaration of Interests

All Directors shall:

  • complete a Declaration of Interests on appointment; 
  • review it annually; 
  • notify the Secretary promptly of any changes. 

The Secretary will maintain a Register of Interests.

6. Declaring Interests at Meetings

At the start of each Board meeting, the Chair will ask whether any Director has an interest in the business to be discussed.

Any declared interest shall be recorded in the minutes.

7. Managing Conflicts

Depending on the nature of the conflict, the Board may decide that the Director should:

  • participate fully; 
  • participate in discussion but not vote; 
  • leave the meeting while the item is discussed; 
  • take no part whatsoever. 

The Chair (or Vice-Chair if the Chair has the conflict) will determine the appropriate course of action, having regard to the CLT’s Rules.

8. Register of Interests

The Secretary will maintain a confidential Register of Interests containing:

  • Director’s name; 
  • date declaration completed; 
  • summary of declared interests; 
  • date last reviewed. 

9. Confidentiality

Information declared under this policy will be treated confidentially and processed in accordance with the CLT’s Data Protection Policy.

10. Failure to Declare

Failure to declare a relevant conflict may constitute a breach of the Director’s duties and may be dealt with under the CLT’s Rules and Code of Conduct.

11. Review

Originally approved by the Board of Greystoke Community Land Trust on [date]
This policy will be reviewed every 3 years.

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