Appendix 10.5
Conflicts of Interest – StreetGames Principles for Identification and Management.
Introduction
StreetGames takes seriously the process of managing the inevitable conflicts of interest that arise in
the day to day functioning of the organisation. We recognise that a network organisation – such as
we are - is particularly vulnerable to actual and perceived conflicts. It is our ambition to make it clear
that StreetGames’ ways of working are transparent.
Our approach and procedures will develop over time. We will use good practice guidelines, initially
informed by the Charity Commission, to shape a StreetGames way of working.
Effective management of conflicts of interest is a whole organisation priority. It runs through from
projects in the network to staff, contractors and Trustees. Appropriate training will therefore be
provided to those staff involved in the assessment and management of conflicts of interest and all
staff will be made aware of their responsibilities in this area through induction and staff meetings.
StreetGames has a separate policy for dealing with Conflicts of Interest relating to Trustees (Policy
13).
For projects in the network, StreetGames will ensure that the expectation to declare conflicts of
interest is built into the procedures for allocating resources e.g. the Doorstep Sport Club application
process.
Definition and risk to StreetGames
A conflict of interest is any situation in which a trustee, contractor or staff member’s personal
interests, or interests which they owe to another body, and those of the charity arise simultaneously
or appear to clash. 1
Conflict of interest is a state of being and not necessarily a practice. The issue is not the integrity of
the individual concerned. It is about the management of a potential to profit from a person’s
position; or the potential for an individual to be influenced by conflicting loyalties. Even the
appearance of a conflict of interest can damage the charity’s reputation, so conflicts need to be
managed carefully. It is important to reinforce that the existence of a conflict of interest does not in
itself suggest inappropriate or illegal behaviour.
How StreetGames will manage conflicts of interest
The first stage in the StreetGames management of conflicts of interest is the identification and
declaration by the individuals concerned. StreetGames is committed to the following actions:
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1
All trustees, staff and contractors to complete and sign declaration of interest forms on
commencing their relationship with StreetGames
Within the agenda, and at the start of all formal governance meetings including Board
meetings, Finance and Audit Committee there will be provision for declaring conflicts.
Adapted from The Charity Commission ‘Charity Requirements and Guidance’
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Appendix 10.5
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Conflicts of interest that arise within the everyday operations of the organisation to be
recorded, along with the decisions taken on their management.
Declaration of interest forms for staff, trustees and contractors to be reviewed and updated
annually and any individual who becomes aware of a new conflict of interest in the interim
period between updates to pro-actively update their details.
Once they have been declared, StreetGames will pro-actively manage conflicts of interest to
maintain the good reputation of the charity and protect our staff, contractors and trustees from the
negative effects that can be created by perceived conflicts.
Each declared conflict of interest will be reviewed on its own merit and a judgement made upon the
appropriate management response.
The assessment process for the management of conflicts of interest relating to staff, contractors and
projects will be as follows:
1. All declarations of interest to be reviewed by the appropriate first-line management. In the
case of StreetGames staff and contractors this will be the Deputy Chief Executive and
Finance Director. For projects applying for resources this will be the functional or
programme lead.
2. Those conflicts warranting further discussion to be shared with the Internal Control Peer
Review Group.
3. Where the Internal Control Peer Review Group is unable to determine the appropriate
response, conflicts to be referred to the Chief Executive for final decision.
4. Where a conflict reaches Stage 3 of the process above (referred to Chief Executive), then
those conflicts and the decisions on their management will be reported to the Audit
Committee.
Where conflicts arise in the course of day-to-day operations, decisions should be recorded and
logged in the Conflict of Interest register of decisions held by the StreetGames Office Manager.
Below are the most common management options for conflicts of interest and how StreetGames will
seek to apply them.
In the active management of conflicts of interest StreetGames will consider:
a) the removal of the individual concerned from any related decision making process
b) the involvement of the individual as one of a decision-making group following a risk/benefit
analysis – the rationale for this to be recorded in the register of decisions
c) asking the individual to completely remove the conflict e.g. by the individual concerned
ceasing their relationship with the other organisation or individual.
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Appendix 10.5
Policy on the management of undeclared interests.
Where any trustee, staff member or contractor is found to have deliberately withheld information
relating to a conflict of interest, whether or not that brings the charity into disrepute and/or puts the
work of the charity at risk financially then the following procedures will apply
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Staff – disciplinary process and potential termination of employment
Contractors – breach of contract and potential termination of contract
Trustee – breach of trust as defined by the Charity Commission and potential removal from
office
Review of the implementation of these principles
This statement of principles will be reviewed every three years in line with the StreetGames Policy
Review cycle through the Finance Committee and its implementation reviewed as part of the cycle
of the StreetGames Audit Committee.
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