Conflict of Interest Policy for Charities: Template & Guide
Free conflict of interest policy template for UK charities. How to identify, declare, and manage conflicts. Essential for trustee governance.
Conflicts of interest are inevitable in charity governance — what matters is how you manage them. A clear policy protects your charity, your trustees, and your reputation.
What is a Conflict of Interest?
A conflict of interest arises when a trustee's personal interests — financial or otherwise — could influence, or could be seen to influence, their decision-making on behalf of the charity.
Common Examples
- A trustee's company bidding for a charity contract
- A trustee's family member applying for a charity job
- A trustee receiving payment for professional services to the charity
- A trustee who is also a trustee of another charity that could compete for the same funding
- A trustee with a personal relationship with a staff member being discussed
Template Policy
Conflict of Interest Policy — [Charity Name]
1. Purpose
This policy ensures that conflicts of interest are identified, declared, and managed transparently.
2. Definition
A conflict of interest is any situation where a trustee's personal interests, or the interests of a connected person, could influence or be perceived to influence their judgment in charity matters.
3. Declaration
All trustees must declare any actual or potential conflicts of interest:
- At the start of every board meeting
- When they arise between meetings
- On appointment (using the Register of Interests form)
4. Register of Interests
The charity will maintain a Register of Interests listing all trustees' declared interests. This will be reviewed annually and updated as needed.
5. Managing Conflicts
When a conflict is declared:
- The conflicted trustee will withdraw from the relevant discussion and decision
- They will leave the room (or virtual meeting) during the discussion
- The remaining trustees will make the decision independently
- The conflict and how it was managed will be recorded in the minutes
6. Exceptions
If a trustee's participation is essential (e.g., their expertise is needed), the board may allow them to provide information but they must still withdraw from the decision. This must be recorded in minutes with the rationale.
7. Trustee Payments
No trustee may receive payment for services to the charity unless explicitly authorised by the governing document and properly managed under this policy.
8. Review
This policy will be reviewed annually by the Board of Trustees.
Best Practice
- Normalise declarations — make it routine, not shameful. "Before we begin, any conflicts to declare?"
- Err on the side of declaring — if in doubt, declare it. Better safe than sorry.
- Keep good minutes — record every declaration and how it was managed
- Update the register annually — interests change; the register should reflect reality
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