# Conflicts of Interest Policy ## Scope Applies to **Trustees**, **Senior Leadership Team (SLT)**, and any individual in a position of authority or trust within Salford SU. Also covers paid staff where relevant (e.g. procurement decisions, grant panels). ## Definition of a Conflict A conflict of interest arises when a personal interest — financial, personal, professional, or relational — could improperly influence a decision made in the organisation's name. This includes: - **Direct financial interest**: holding shares, loans, or financial benefit from a supplier/partner - **Indirect financial interest**: a close associate (family member, partner) benefits - **Non-financial personal interest**: personal loyalty to an individual or organisation that could bias a decision - **Loyalty conflicts**: serving on another board or organisation with competing interests ## Register of Interests All Trustees and SLT members must maintain an up-to-date **Register of Interests**. Entries must be updated: - On appointment - Annually (at start of each academic year) - Within 28 days of any material change The register is maintained by the Governance team and is available for inspection by the Board. ## Declaration Thresholds | Item | Threshold | Action | |------|-----------|--------| | Gifts received | Over £25 | Declare and record | | Hospitality received | Over £100 | Declare and record | | Gifts/hospitality offered | Any value | Declare and record | | Financial interests | Any | Declare immediately | | Board/committee appointments | Any external | Declare immediately | ## Managing a Declared Conflict When a conflict is declared in a meeting: 1. The individual **declares** the conflict at the start of the relevant agenda item 2. The Chair determines whether the conflict is **material** (likely to influence the decision) 3. If material: the individual **withdraws** from the discussion and vote, and this is minuted 4. If not material: the Chair notes the declaration and the individual may participate For Trustee conflicts, the procedure follows the **Articles of Association** provisions on interested parties (Company law requirements apply — an interested trustee cannot vote on a matter where they have a personal financial interest). ## Gifts and Hospitality - All offers of gifts or hospitality above thresholds must be **declined or declared** immediately - Accepted gifts (under threshold) must be logged in the central register - Repeated small gifts from a single source should be treated as a single cumulative gift - The SU does not give gifts to external parties that could be perceived as an inducement ## Excerpt from Articles of Association (embedded in policy) The policy includes relevant extracts confirming Trustees may not be paid for their services (other than out-of-pocket expenses) without Charity Commission consent, and that transactions with connected persons require full Board approval. ## Key Contacts - **Governance queries**: CEO (Ed Moloney) - **Trustee Register of Interests**: Company Secretary / Governance team