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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Conflicts of Interest Policy

1. Purpose

The purpose of this policy is to ensure that all operations at {{org_field_name}} are carried out with the utmost integrity, transparency, and fairness, especially where staff or organisational decisions could be influenced by competing interests. This policy sets out the procedures to identify, declare, and manage any actual, potential, or perceived conflicts of interest to protect the wellbeing of the people we support and maintain the highest standards of professional and ethical conduct.

Conflicts of interest, if not properly managed, can lead to partial decision-making, loss of trust, reputational damage, or regulatory non-compliance. This document outlines how our service proactively prevents and deals with such conflicts in a manner that prioritises openness and public confidence in our care.

2. Scope

This policy applies to all individuals working or acting on behalf of {{org_field_name}}, including:

• All full-time and part-time employees
• Volunteers
• Bank, agency, and sessional workers
• Contractors and external professionals engaged with the service
• Management and governance representatives, including directors and board members

It applies across all domains of service activity, including but not limited to recruitment, care planning, resource allocation, purchasing or commissioning of services, supervision, and the handling of finances. It also applies to relationships with individuals we support and their families, where boundaries must remain clearly professional at all times.

3. Legislation, standards and regulatory guidance

{{org_field_name}} will implement this policy in line with relevant legislation, standards and regulatory guidance, including:

• the SSSC Codes of Practice for Social Service Workers and Employers (effective from 1 May 2024), including Code 2.6 (conflicts of interest) and Code 2.7 (gifts and money).
• the Health and Social Care Standards (used by the Care Inspectorate to inform quality judgements).
• the Care Inspectorate quality framework for support services (care at home, including supported living).
• the Care Inspectorate “Guidance on records you must keep and notifications you must make (adult care services)” (published 27 March 2025), including statutory timescales for notifying protection concerns and allegations of staff misconduct.
• the Bribery Act 2010 (UK-wide) in relation to inducements, gifts and improper advantage.
• the Disclosure (Scotland) Act 2020 implementation changes from 1 April 2025 where relevant to recruitment/referrals linked to harm or risk of harm.

4. Related Policies

This policy complements and should be read in conjunction with the following documents:

• Code of Conduct and Professional Boundaries Policy
• Whistleblowing Policy
• Recruitment Policy
• Confidentiality and Information Sharing Policy
• Financial Transactions and Handling of Money Policy
• Safeguarding and Protection from Abuse Policy
• Complaints and Feedback Policy

5. Policy Statement

{{org_field_name}} is committed to the highest standards of ethical conduct and accountability in all areas of service delivery. We recognise that staff may encounter situations where their personal or financial interests—or those of close family members, friends, or associates—could influence their decisions, actions, or responsibilities. Our aim is to ensure that such situations are managed appropriately and do not affect the quality of care provided to people we support.

All staff are expected to act in the best interests of those we support, to avoid any situation that might compromise—or appear to compromise—their judgement, and to promptly report any conflicts that arise. Any failure to manage conflicts appropriately can result in disciplinary action and may be referred to regulatory bodies such as the SSSC or Care Inspectorate.

6. Definitions

A conflict of interest occurs when an individual’s ability to exercise judgement in their professional role is compromised—or could be perceived to be compromised—by competing personal, financial, or emotional interests.

Types of conflicts include:

• Actual conflict: A real and existing situation where personal interest directly interferes with professional responsibilities.
• Potential conflict: A situation where the risk of conflict could arise in future circumstances.
• Perceived conflict: A situation where others may reasonably believe that a conflict exists, even if none is present.

Examples of conflicts include:

• Engaging in a personal or romantic relationship with a person receiving care or their relative
• Recommending or purchasing products or services from a company owned by a friend or family member
• Accepting gifts, money, or favours from people we support or their relatives
• Working a second job that overlaps with your role at {{org_field_name}} and could create a divide in loyalty or priorities

7. Responsibilities

Staff Responsibilities

All employees have a professional duty to identify and report any conflicts of interest at the earliest opportunity. They must not allow personal gain, loyalty, or relationships to compromise their professional judgement, nor should they use their position for undue advantage for themselves or others.

Staff must:

• Disclose any real or potential conflicts as soon as they become aware of them
• Avoid actions or decisions that could be influenced by personal interests or relationships
• Seek advice from their line manager if uncertain whether a situation constitutes a conflict

Under the SSSC Codes of Practice, social service workers must declare issues that might create conflicts of interest (Code 2.6) and follow policies and procedures about exchanging gifts and money with individuals and carers (Code 2.7).

Line Manager Responsibilities

Line managers are expected to take all declarations seriously, maintain confidentiality, and take steps to mitigate the conflict. This may involve reassignment of duties, implementing monitoring arrangements, or in some cases, requiring the staff member to withdraw from a situation entirely.

Managers must:

• Assess reported conflicts and decide on appropriate action
• Provide guidance to staff on managing boundaries and avoiding conflicts
• Ensure that all incidents are recorded in the Conflicts of Interest Register

Registered Manager Responsibilities

The Registered Manager ({{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}) is responsible for the overall oversight and governance of this policy. This includes:

• Ensuring all staff understand the policy and receive appropriate training
• Maintaining a current and secure Conflicts of Interest Register
• Ensuring that where a conflict of interest (declared or suspected) indicates a protection concern or potential harm to a person using the service, the service follows the Care Inspectorate notification guidance for adult services and submits the relevant eForms within required timescales (including within 24 hours where applicable), and provides follow-up/update notifications as required.

Nominated Individual Responsibilities

The Nominated Individual ({{org_field_nominated_individual_first_name}} {{org_field_nominated_individual_last_name}}) provides additional governance by:

• Reviewing the Conflict of Interest Register on a quarterly basis
• Ensuring that systemic risks are identified and addressed at a strategic level

8. Declaration and Disclosure Process

At Recruitment

During recruitment, candidates will be asked to declare any existing conflicts as part of their pre-employment checks. This information will be considered when allocating roles to ensure impartiality and suitability.

Throughout Employment

Staff must immediately inform their line manager using the Conflict of Interest Disclosure Form if:

• Their circumstances change (e.g., a new relationship with a person we support develops)
• A new outside business interest or secondary employment is taken on
• They become aware of a situation that could lead to a potential conflict

Annual declaration
In addition to ad-hoc disclosures, all staff, directors and board members must complete an annual conflict of interest declaration, even where they believe they have “nothing to declare”.

High-risk financial conflicts
Staff must not:

• act as, or seek to become, a welfare/financial power of attorney, appointee, executor, beneficiary or trustee for a person using the service (or their close relative), or accept any legacy/loan, unless this is expressly permitted by law and has been formally assessed and authorised in writing by the Registered Manager and Nominated Individual with independent advice recorded.
  Any approach/request of this nature must be declared immediately and recorded in the Conflicts of Interest Register.

Failure to report a conflict may be regarded as a disciplinary matter.

Conflict of Interest Register

All declarations will be recorded in a confidential Conflict of Interest Register maintained by the Registered Manager. This register includes:

• The name of the staff member
• Nature and context of the conflict
• Date reported and reviewed
• Actions taken to resolve or manage the conflict
• Whether the conflict relates to gifts/hospitality, secondary employment, procurement/commissioning, or personal relationships with a person using the service
• Any restrictions/controls agreed (e.g., reallocation of visits, removal from decision-making, supervision/monitoring arrangements)
• Whether the matter triggered Care Inspectorate notification, safeguarding referral, SSSC/Disclosure Scotland referral, or internal disciplinary process (including dates submitted)

The register is reviewed quarterly, or more frequently if significant conflicts are identified.

9. Managing Conflicts

Where a conflict of interest is identified, {{org_field_name}} will assess its potential impact and determine a proportionate response. Possible mitigation strategies include:

• Reallocating duties to another staff member
• Ensuring supervision or oversight by a neutral party
• Declining or returning gifts or favours
• Recusal from decision-making processes

All actions will be documented and followed up through supervision and internal audit.

10. Training and Communication

All staff will receive training on recognising and managing conflicts of interest during their induction. Refresher training will be provided annually, incorporating real-life case scenarios to reinforce understanding. Staff will also be reminded of their duties through team meetings, supervision, and internal bulletins.

11. Breaches of Policy

Any failure to disclose or appropriately manage a conflict of interest will be treated seriously and may result in disciplinary action up to and including dismissal.

Where a conflict of interest results in, or indicates, a protection concern or potential harm to a person using the service, {{org_field_name}} will follow the Care Inspectorate notification guidance for adult services and will submit the relevant eForms notifications within required timescales (including within 24 hours where required). This includes:

• submitting a ‘Protection concern about a person using the service’ notification within 24 hours, and providing an update within one month; and
• where the concern involves staff, submitting ‘Allegation of Misconduct by Provider or Persons Employed in the Care Service’ and making referrals to the relevant professional body (for example the SSSC) and Disclosure Scotland where required.

In addition, serious concerns may be escalated to the Nominated Individual and, where appropriate, to commissioning/safeguarding partners in line with local adult protection procedures.

12. Whistleblowing and Raising Concerns

All staff are encouraged to report suspected or undeclared conflicts of interest using the organisation’s Whistleblowing Policy. Reports may be made anonymously and without fear of reprisal. Concerns will be investigated thoroughly and fairly, and any necessary actions will be taken to protect people we support and uphold organisational integrity.

13. Policy Review

This policy will be reviewed on an annual basis or earlier if required by changes in legislation, regulation, or operational practice. Reviews will be conducted by the Registered Manager and Nominated Individual, with any amendments communicated to all staff.

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Responsible Person: {{org_field_registered_manager_first_name}}{{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
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