Catch22 reserves the right to amend this policy, following consultation, where appropriate.
Date of last review: June 2023
Date of next review: June 2024
What is the policy about?
This policy sets out Catch22’s rules and expectations covering how to avoid the creation of any perception of a conflict of personal and organisational interests. This policy must be read in conjunction with the Code of Conduct Policy.
Who is the policy for?
This policy covers all Catch22 employees, Trustees, and those representing the organisation, referred to as ‘staff’ in this policy (this includes agency workers, sole traders and the self employed or any worker who could be perceived as representing Catch22).
All Catch22 staff must ensure that your individual private or personal interests do not influence decisions made on behalf of Catch22 and that you do not use your position to obtain personal gain of any sort. Equally you must avoid creating any perception of a conflict of interest e.g. certain political activities or business interests might give rise to a perception of conflict of interests that could be anticipated – even though you may act entirely properly and not allow this to influence your behaviour at work.
It is your responsibility to declare actual and/or the potential for perceived conflicts of interest, and to strive to ensure that they do not influence judgement or practice.
You are expected to be meticulous about informing your manager of any conflicts of interest or activities which may give rise to a perception of such.
Gifts and hospitality
To avoid a conflict of interest, the appearance of a conflict of interest, or the need for our employees to examine the ethics of acceptance, our company, and its employees do not accept gifts from vendors, suppliers, customers, potential employees, potential vendors or suppliers, or any other individual or organisation, except under exceptional circumstances as detailed in the examples below:
- Gifts offered by service users where staff should avoid accepting gifts or hospitality of more than nominal value, as this may be perceived as placing an individual under an obligation. Situations may arise where refusal of a small gift from a service user may damage the relationship with the service worker; advice from the Line Manager should be sought in order to clarify the propriety of any such case. If the decision is that a gift can be accepted then it should be recorded on the file of the service user concerned, and a note of thanks should be sent.
- Gifts offered at Christmas or other occasional times in the year from existing suppliers or vendors such as a diary or a box of chocolates or biscuits. These gifts often are sent without notice and should never be requested but may be accepted on the basis of there being no expectation of additional service or incentive to renew a contract or order being attached.
- Any gift offered as part of signing up to a subscription or service, which would have been undertaken irrespective of the incentive being offered, must be declared to your line manager and noted in the gifts and hospitality register.
If you have any doubts as to whether it is appropriate to accept the gift being offered you must refer it to a senior manager prior to accepting it.
Catch22 requires that all employees demonstrate our organisation’s commitment to treating all people and organisations, with whom we come into contact or conduct business, impartially. Catch22 employees demonstrate the highest standards of ethics and conduct.
Employees must practice and demonstrate equal treatment, unbiased professionalism, and nondiscriminatory actions in relation to all vendors, suppliers, customers, employees, potential employees, potential vendors or suppliers, and any other individual or organisation.
Hospitality must not be accepted if it could be seen as a way of exerting improper influence over the organisation and a note of any hospitality that is accepted (aside from small items such as occasional soft drinks) must be made and included in notes of Supervision. A Gifts and Hospitality Register must be held in each service location. Gifts and hospitality must be formally recorded in the register, apart from inexpensive items such as working meals at office locations, or free calendars. A template register can be requested from Finance.
In respect of the giving of gifts or provision of hospitality to others reference must be made to Catch22’s Anti-Bribery Policy (as these may fall under the scope of the Bribery Act 2010) and Conflicts of Interest policies which are essential reading for all. No gifts of significant monetary value are to be given or offered to other people or organisations. This does not apply to such things as birthday or Christmas presents to service users which are given in line with agreed local policy and practice (this expressly includes gifts given in private capacity). These will be dealt with through the service’s normal procedures and practices on such matters.
Additional (external) work
You must discuss the possibility of taking up additional work with another employer (including casual or temporary work for agencies) or pursuing a personal business interest/opportunity with your manager and obtain consent in writing before so doing. This is to ensure that the additional work/business interest does not:
- Conflict with the Charity’s interests or reasonably cause a perception of such
- Fail to comply with the Working Time Regulations, the responsibility for which is with Catch22 as the substantive employer – the regulations being not more than an average of 48 hours per week over a 17 week period
- Cause detriment to the service being delivered by Catch22.
Other conflicting interests
All potential or actual conflicts of interest or circumstances that may give rise to a perception or suspicion of a conflict of interest, must be declared, in writing, at the earliest possible stage to the relevant senior manager (Director, Assistant Director, Executive Principal or Head of Function). The senior manager will determine how best to respond to avoid potential difficulties both for the organisation and the employee. The interests of the organisation in such circumstances will always be the over-riding factor.
Records and Management responsibilities
Managers must make a note of and inform the relevant Director, Assistant Director, or Head of Function of any declarations of an actual, pending or perceived conflict of interest or request to undertake additional work/new business interest that may give rise to such. These managers will agree whether steps can be taken that will safeguard the charity from the impact of such a conflict and if so will agree these actions with the relevant Director.
Depending on the circumstances, it may be necessary for the Charity to take further action to protect the interests/reputation of either the staff member, other staff, service users, the Charity or others. People Partners will need to be advised and consulted.
Any steps necessary must be explicitly agreed with the member of staff and a note recording the agreement, with the signature of all parties, sent to HR for inclusion on the employee’s personal file. Where there is a failure to reach agreement Catch22 reserves the right to take any action necessary to protect its interests and reputation. This may include use of the disciplinary policy.
- Anti-bribery policy
- Anti-money laundering policy
- Procurement policy
- Code of conduct