Conflicts of Interest, Gifts and Hospitality Policy

Actual, potential or perceived conflicts must be disclosed before a person participates in a relevant decision. Examples include financial interests, family or close personal relationships, outside employment, competing duties and personal benefit from a supplier or customer decision.

The relevant business records the conflict and decides whether it can be managed through disclosure, independent approval, restricted access, withdrawal from the decision or another proportionate control.

Gifts and hospitality may be accepted or offered only when they are lawful, modest, infrequent, transparently recorded where material, and not intended or likely to influence a decision. Cash, cash equivalents, secret commissions and benefits connected to an improper outcome are prohibited.

Particular caution applies during tenders, contract awards, disputes, inspections and regulatory decisions. Where there is doubt, the gift or hospitality must be declined or approved in advance by the responsible business.

A conflict may be actual, potential or perceived and may arise from family or personal relationships, financial interests, outside work, competing duties, former employment, supplier relationships, confidential information or involvement in a decision affecting the person. The duty is to declare early; a declaration is not itself wrongdoing.

The relevant business records the people, interest, decision, risk and agreed safeguards. Controls may include disclosure, independent quotation or approval, recusal, restricted information, removal from supervision, divestment or refusal of the transaction. A person with the conflict does not approve their own management plan.

Gifts and hospitality must be modest, infrequent, transparent, lawful, connected to a legitimate business purpose and incapable of reasonably appearing to influence a decision. Cash and cash equivalents, secret benefits, personal supplier rebates, lavish or repeated hospitality and benefits during a live tender or dispute are prohibited. Declined offers may also be recorded where they reveal attempted influence.

Registers are reviewed for patterns across the giver, recipient, procurement and timing. Charitable donations, sponsorship, travel and accommodation receive equivalent scrutiny and written authority. Local custom or customer pressure does not override this policy.

Suspected concealment or improper influence is reported through the relevant business's published concern route and considered under the Anti-Bribery, Corruption and Fraud Policy.

Approved by David Swaddle, Founder, on 30 August 2026.