Resources / Conflicts of interest policy and register
Conflicts of interest policy and register
Trustees must not let personal interests conflict with the charity's — and must be able to show conflicts were managed (CC29). That takes three things: a policy, a register, and a habit at meetings. All three are below; adapt the wording to your charity.
Policy template (adapt freely)
[Charity name] — Conflicts of Interest Policy
1. Purpose. Trustees have a legal duty to act only in the charity's best interests. This policy explains how we identify, declare and manage conflicts of interest and conflicts of loyalty.
2. What counts. A conflict exists whenever a trustee's personal, family, business or other interests could affect — or could appear to affect — their decision-making. This includes benefits to connected persons and duties owed to other organisations.
3. Register of interests. Every trustee completes a declaration on appointment and renews it annually, including nil returns. The secretary maintains the register and presents it to the board annually.
4. At every meeting. Declarations of interest are a standing agenda item. A trustee with a conflict on any item declares it before discussion.
5. Managing a declared conflict. Unless the board decides a lesser step is adequate, the conflicted trustee withdraws from discussion and does not vote; the minutes record the conflict and the action taken. Where the governing document or law requires it (e.g. trustee benefit), the stricter rule applies.
6. Trustee benefit. No trustee may receive payment or material benefit from the charity except as permitted by the governing document and law, and only following the required authorisation.
7. Review. The board reviews this policy every two years. Owner: [Chair/Secretary]. Adopted: [date]. Next review: [date].
Register of interests — columns
Trustee · interest type (financial / loyalty / connected person) · description · date declared · how managed · date lapsed. Keep nil returns too — they prove the question was asked.
The meeting habit
Minute wording: "Cllr Amara Okafor declared a conflict on item 5 (grant to Riverside Youth Club) as a member of its management committee. She answered trustees' factual questions, then withdrew for the discussion and vote. Decision taken in her absence: grant approved."