Conflicts of Interest Policy

1. Purpose of this Policy
   Pamphill Parish Hall is a charity. Trustees and committee members must act only in the best
   interests of the charity and avoid situations where personal interests conflict, or could
   reasonably be perceived to conflict, with those interests.
   This policy sets out how Pamphill Parish Hall will:
   • Identify conflicts of interest
   • Ensure they are declared properly
   • Manage them in line with Charity Commission guidance CC29

2. What Is a Conflict of Interest?
   A conflict of interest occurs when a trustee’s or committee member’s personal interests or
   loyalties could prevent, or be seen to prevent, them from making a decision solely in the
   best interests of Pamphill Parish Hall.
   Conflicts may be:
   • Financial
   For example:
   o Being paid by Pamphill Parish Hall
   o Supplying goods or services to Pamphill Parish Hall
   o Employment or business interests connected to a decision
   • Loyalty (non-financial)
   For example:
   o Family or close personal relationships
   o Membership of another organisation that is dealing with Pamphill Parish Hall

Conflicts may be:
• Actual – currently affecting a decision
• Potential – could arise in the future
• Perceived – could reasonably be seen by others as a conflict
3. Who This Policy Applies To
This policy applies to:
• Trustees
• Committee members
• Volunteers with decision-making authority

• 4. Trustee Duties (CC29 Principles)
5. Declaration of Interests
All trustees and committee members must:
• Declare any relevant interests on appointment
• Update their declaration whenever circumstances change
• Declare any conflict of interest at the start of meetings where it arises
Declarations should include interests of:
• The individual
• Close family members or partners
• Businesses or organisations in which the individual has an interest
6. Register of Interests
Pamphill Parish Hall will maintain a Register of Interests which:
• Records all declared interests
• Is reviewed annually
• Is available to trustees and committee members
7. Managing Conflicts of Interest
When a conflict of interest arises, Pamphill Parish Hall will follow the CC29 three-step
approach:
Step 1 – Identify
The conflict is identified and declared as soon as it becomes apparent.
Step 2 – Prevent the Conflict from Influencing the Decision
• The conflicted person must not take part in discussions or decisions
• They should normally withdraw from the meeting for that agenda item
Step 3 – Record
• The conflict and how it was managed must be clearly recorded in the minutes
The Chair will decide how the conflict is managed.
If the Chair has a conflict, this role will be taken by another unconflicted trustee.
8. Payments and Trustee Benefits

Trustees and committee members must not receive any financial benefit from Pamphill
Parish Hall unless:
• It is explicitly permitted by law and Pamphill Parish Hall’s governing document
• The conflict has been declared
• The decision is made by trustees with no conflict of interest
• The benefit is clearly in the best interests of Pamphill Parish Hall
Any such decision must be fully recorded.
9. Failure to Declare a Conflict
Failure to declare a conflict of interest may:
• Put trustees in breach of their legal duties
• Result in decisions being reviewed or overturned
• Lead to removal from office in accordance with Pamphill Parish Hall’s governing
document
10. Review of Policy
This policy will be reviewed annually, or sooner if Charity Commission guidance or
legislation changes.